United States v. Morrison case brief

United States v. Morrison case brief summary

529 U.S. 598 (2000)

CASE SYNOPSIS

Petitioner victim appealed the judgment of the United States Court of Appeals for the Fourth Circuit declaring unconstitutional 42 U.S.C.S. § 13981, which provided a civil remedy for the victims of gender-motivated violence, on the ground that Congress lacked the authority to enact the statute under either the Commerce Clause or U.S. Constitutional amendment XIV, § 5.

CASE FACTS
Petitioner victim brought an action against respondent offender under 42 U.S.C.S. § 13981, which provided a federal civil remedy for the victims of gender-motivated violence. The lower court struck down § 13981 and concluded that Congress lacked constitutional authority to enact the statute under either the Commerce Clause or U.S. Constitutional amendment XIV, § 5. The court rejected petitioners' argument that § 13981 was a regulation of activity that substantially affected interstate commerce.

DISCUSSION

• The court affirmed the decision of the lower court and held that gender-motivated crimes of violence were not considered economic activity, and therefore, the Commerce Clause did not vest Congress with the authority to enact a statute regulating such. 
• Moreover, the court affirmed that the civil remedy contained in § 13981 should be struck down as it was outside Congress's remedial power under U.S. Constitutional amendment XIV, § 5. 
• The civil remedy was not found to be corrective in its character nor adapted to counteract and redress the operation of such prohibited state laws or proceedings of state officers. 
• Instead, the subject statute redressed private discrimination and was outside Congress' power to enact.

CONCLUSION
The court affirmed and held that Congress lacked the authority to enact the subject statute under the constitution because the statute did not involve economic activity or interstate commerce.