United States v. Comstock case brief

United States v. Comstock case brief summary

130 S.Ct. 1949 (2010)

CASE SYNOPSIS

A district court granted respondent inmates' motion to dismiss petitioner United States' (U.S.) civil commitment proceeding under 18 U.S.C.S. §§ 4247, 4248(a), finding that in enacting § 4248, Congress exceeded the powers granted to it by the Necessary and Proper Clause, U.S. Constitutional Article I, § 8, cl. 18. The United States Court of Appeals for the Fourth Circuit upheld the dismissal. Certiorari was granted on the request of the U.S.

DISCUSSION

• The Necessary and Proper Clause granted Congress broad authority to criminalize conduct, imprison those who engaged in that conduct, and enact laws governing prisons and prisoners in the course of "carrying into Execution" the enumerated powers "vested by" the "Constitution in the Government of the U.S.,"--authority granted by the Necessary and Proper Clause. Section 4248 was a modest addition to a set of federal prison-related mental-health statutes that had existed for many decades, aside from its focus on sexually dangerous persons. 
• The desire to address the specific challenges identified with mentally ill, sexually dangerous federal prisoners, taken together with U.S. responsibilities as a federal custodian with the constitutional power to act to protect communities from the danger its prisoners could pose, satisfied a rational means review. 
• Powers granted by the Necessary and Proper Clause were, by definition, not powers "reserved to the States" under U.S. Constitutional amendment X, and, § 4248 even required accommodation of state interests. 
• Section 4248 was not too sweeping in scope. From the implied power to punish, the federal civil-commitment power was inferred.

CONCLUSION

The Fourth Circuit's judgment was reversed and the case was remanded for further proceedings. 7-2 Decision; 1 opinion, 2 concurrences; 1 dissent.