United States v. Morrison

The Court struck down the civil damages provision of the Violence Against Women Act as beyond federal power.

Overview

Christy Brzonkala sued her alleged assailants under a federal statute creating a damages remedy for gender-motivated crimes of violence. Chief Justice Rehnquist, for a 5-4 majority, held that gender-motivated crimes are not economic activity, and that congressional findings of aggregate national effects could not convert them into interstate commerce; the Fourteenth Amendment could not supply power over private actors either. Morrison, together with Lopez, marked the outer boundary of the commerce power and demonstrated the Court's willingness to invalidate major federal enactments on structural grounds.