United States v. Morrison
Citation and Court
529 U.S. 598 (2000). United States Supreme Court. Chief Justice Rehnquist, writing for the Court (5-4).
Facts
Christy Brzonkala, a student at Virginia Tech, alleged that she was raped by two football players, Antonio Morrison and James Crawford. She brought a civil suit under the Violence Against Women Act (VAWA), which Congress had enacted pursuant to both the Commerce Clause and Section 5 of the Fourteenth Amendment. Congress had compiled extensive legislative findings documenting the economic costs of gender-motivated violence. The district court dismissed, and the case reached the Supreme Court on whether Congress had power to enact VAWA’s civil remedy provision.
Issue
Does Congress have power under the Commerce Clause or Section 5 of the Fourteenth Amendment to enact a federal civil remedy for victims of gender-motivated violence?
Holding
No. Gender-motivated violence is not economic activity and does not substantially affect interstate commerce; therefore, Congress cannot regulate it under the Commerce Clause. Section 5 power applies only to state action, not private conduct.
Rule / Doctrine
Limits on the Commerce Clause — Non-Economic Activity: Congress cannot regulate non-economic, violent criminal activity merely because it has some aggregate effect on commerce. The substantial effects test applies only to economic activity; extending it to non-economic activity would give Congress a general police power. Key limiting principles from United States v. Lopez (1995) were reaffirmed: courts must distinguish between truly national and truly local activity, and look for a jurisdictional element or substantial nexus to commerce.
Significance
Morrison is the second major Rehnquist Court Commerce Clause federalism decision, following Lopez. Together they create hard outer limits on the aggregation principle established in Wickard v. Filburn. The Section 5 holding is equally important: it established that Congress’s enforcement power under the Fourteenth Amendment cannot reach purely private conduct, only state action. Morrison demonstrates the Court’s willingness to strike down popular federal legislation on structural federalism grounds.