Structure of Government: Legislative Power - Commerce Clause Flashcards
Gibbons v. Ogden
Facts: Ogden was given an exclusive license, pursuant to a New York statute, to run a ferry between New York and New Jersey. Gibbons obtained a license, pursuant to federal law, to run a ferry in New York waters, thus, running in interference with Ogden’s license. Ogden sought an injunction against Gibbons.
Holding: Congress’ power to regulate interstate commerce does not stop at the external boundary line of a State. Congress’ power to regulate within its sphere is exclusive.
Champion v. Ames
Facts: Appellant is an express carrier challenging the constitutionality of an act of Congress prohibiting the carriage of lottery tickets across state lines.
Holding: Congress has the ability to regulate transport of goods in interstate commerce when such regulation does not affect the internal affairs of the states.
Hammer v. Dagenhart
Facts: The Child Labor Act prohibited the interstate transportation of goods produced with child labor. The father of two children sought an injunction against the enforcement of the Act on the grounds that the law was unconstitutional.
Holding: The power of Congress to regulate commerce does not include the power to regulate the production of goods intended for commerce.
United States v. Darby
Facts: Darby was charged with violating the Fair Labor Standards Act by failing to comply with minimum wage and hour requirements for employees. He challenged the violation, claiming the regulation on intrastate wages and hours did not fall within the commerce powers of Congress.
Holding: If the regulated intrastate activity has a substantial effect on interstate commerce, Congress may regulate the activity regardless of Congress’s motive.
Wickard v. Filburn
Facts: Filburn produced wheat only for personal and local consumption. He was penalized for growing wheat in excess of his allotment allowed by the Department of Agriculture.
Holding: Congress may regulate the activities of entities totally apart from interstate commerce, if those activities affect interstate commerce.
Heart of Atlanta Motel v. United States
Facts: Prior to passage of the Civil Rights Act of 1964, Heart Atlanta Motel, Inc. operated a motel which refused accommodations to blacks. Heart of Atlanta intended to continue this behavior to challenge Congress’ authority to pass the Act.
Holding: Congress may regulate the ability of commercial institutions to deny service on the basis of race under its power to regulate interstate commerce.
Katzenback v. McClung
Facts: Ollie’s barbeque in Alabama refused to serve Negroes.
Holding: Congressional power to regulate commerce can reach seemingly local activities if there is a connection to national commerce.
New York v. United States
Facts: A federal statute required states to either provide for radioactive waste disposal or take title to waste made within the state’s borders. New York claims the statute is an impermissible violation of state sovereignty.
Holding: Congress does not have the power to force states to implement regulations.
Printz v. United States
Facts: Printz and other chief law enforcement officers from the states of Montana and Arizona argue the constitutionality of a congressional action compelling state officers to execute federal law.
Holding: The federal government may not compel the states to enact or administer a federal regulatory program.
United States v. Lopez
Facts: The Gun-Free School Zones Act of 1990 made possessing a gun within a school zone a federal offense. Lopez) was convicted of violating the Act when he brought a handgun to his high school.
Holding: The power of Congress to regulate activities extends only to those activities that substantially affect interstate commerce. The Act neither regulates commercial activity, nor contains a requirement that the possession be connected in any way to interstate commerce.
United States v. Morrison
Facts: Morrison was sued under part of the Violence Against Women Act of 1994, which penalized crimes of violence motivated by gender. Morrison argues this section of the Act is beyond the scope of Congress’ power to regulate commerce.
Holding: Intrastate actions must be economic in nature to be viewed in aggregate by courts reviewing a Commerce Clause case.
Gonzalez v. Raich
Facts: California passed the “Compassionate Use Act,” which allowed for the use of medical marijuana. The Defendants were compliant with state laws when arrested, but guilty under federal DEA laws at the time. The Defendant sued the Attorney General, arguing that Congress had exceeded their interstate commerce clause authority in legislating the behavior of a local citizen, consuming a locally grown herb in his own home.
Holding: Law upheld. Congress may regulate intrastate activity where the behavior, in the aggregate, can impact interstate commerce.
South Dakota v. Dole
Facts: Appellant alleges that the federal withholding of a small percentage of highway funds to states allowing public possession or purchase of alcohol by individuals under 21 years is unconstitutional.
Holding: Non-coercive financial incentives by Congress are a constitutional exercise of the taxing and spending power.
City of Boerne v. Flores
Facts: Congress’ enactment of the Religious Freedom Restoration Act (RFRA) of 1993 was held by the SC to be an excessive use of power under Sec. 5 of the 14thAmendment of the Constitution.
Holding: While preventive rules are sometimes appropriate remedial measures, there must be a congruence between the means used and the ends sought to be achieved. The appropriateness of remedial measures must be considered in light of the evil presented.
National Federation of Independent Business v. Sebelius
Facts: Parties sued alleging Acts were unconstitutional and outside Congress’s taxing power.
Holding: Court upheld Congress’s power to enact most provisions of the Patient Protection and Affordable Care Act (ACA) and the Health Care and Education Reconciliation Act (HCERA), including a requirement for most Americans to have health insurance by 2014.
