Constitutional cases briefing

McCulloch v. Maryland, 17 U.S. (4 Wheat.) 316 (1819)

Facts: the second bank of the United States was chartered by congress following which many branches were established in various states including Baltimore, Maryland. An act imposing a tax on the banks that were not chartered by congress was enacted by the Maryland legislature. McCulloch violated this act and was sued.

Procedural history: McCulloch was sued in Baltimore county court where he was convicted; the court of appeal affirmed this decision, following which he then brought this appeal

Issue: the US constitution is the supreme law and any state laws enacted should not interfere with federal laws passed within this constitution’s scope. Is there any authority under the constitution that congress can establish a United States bank?

Holding: the court ruled in the affirmative.

Judgment: the decision of the court of appeal was reversed. States are under an obligation not to enact and pass laws that are likely to destroy the legislated federal laws

Reasoning: the constitution of the United States is the supreme law and all other state laws should not be inconsistent with it.

NLRB V. Jones & Laughlin Steel Corp., 301 U.S. 1 (1937)

Facts: the constitutionality of the National Labour Relations Act of 1935 was challenged. The national Labour relations board found that the defendant company was violating some of the provisions of the act by firing some of its employees that were engaged in union activities. They gave them an order to stop such discriminatory practices but the defendant refused to adhere to it.

Procedural history: the board sought to enforce the order in the court of appeal but the court found that it was outside the ambit of federal power. An appeal was then brought to the Supreme Court

Issue: congress only has power to regulate activities in states that only have the potential to significantly affect the commerce between states, so in this case, did it have power to regulate these employment practices?

Holding: yes, the board had the power to regulate the activities of the defendant company since these activities went beyond the state they were established in and had effect on other states

Judgment: the court of appeal’s judgment was reversed. The court found that congress possessed the power to regulate such employment practices as long as they had an effect on the interstate commerce

Reasoning: a failure to regulate such activities is likely to have a negative impact not only on the commerce of the concerned state but also on others as the activities of such companies will usually have a beyond the boarder effect

United States v Morison, 529 U.S. 598 (2000)

Facts: Brzonkala, the complainant in this case was enrolled in Virginia Tech in the 1994 fall. She brought allegations that she was constantly assaulted sexually by the defendant amongst others which caused her emotional trauma causing her to even drop out of the institution. She sued under the violence against women act (1994) under which there was a clause that penalized violent crimes motivated by gender. The respondent argued that this went beyond the scope of the commerce power of congress to regulate crime

Procedural history: the complaint was launched in the district court which found in favor of the defendant, that congress lacked the power to enact the act, three judge panel of the fourth circuit court of appeal however reversed it but later a four judge panel affirmed the findings of the district court which then led to this appeal by the complainant and the united states

Issue: is the section that criminalized crimes of violence on basis of gender under the act, a rightful exercise of the commerce power of congress?

Holding: this is not the case; the court of appeals findings were affirmed

Judgment: it was entered in favor of the defendant. Commerce power of congress did not extend this far.

Reasoning: the court reasoned that acts of violence against women don’t in any way affect commerce between states under which the power of congress can be exercised.

Wickard v. Fillburn, 317 U.S. 111 (1942)

Facts: the appellee in this case owned and operated a small farm in Ohio where among other things related to farming, he grew wheat in the winter in limited amounts for his own personal consumption or local consumption. In 1941 however he faced penalties on the basis that he had grown wheat in excess of his allotment under the agriculture’s department. He sued the secretary of agriculture, wickard, arguing that the excess wheat was produced for his own consumption and therefore his activities did not fall under the ambit of the commerce clause.

Procedural history: the district court agreed with him (filburn) and found that the regulations of congress were not constitutional; this was affirmed by the court of appeal, which led to this appeal by wickard

Issue: is it constitutional for congress to regulate intrastate activities that have no effect on other states under the commerce clause?

Holding: the court held in the affirmative, that it is.

Judgment: the court of appeals ruling was reversed and remanded

Reasoning: the court reasoned that though the wheat was necessarily for the personal consumption of the appellee, when viewed in the aggregate nature, this was likely to lower the demand for wheat which would eventually affect the nature of commerce between states.

United States v. Lopez, 514 U.S. 549 (1995)

Facts: the 1990 gun-free school zones act made it an offense to possess a gun within a school zone. Lopez who was a 12th grade student was found in possession of handgun in school following which he was convicted of violating the provisions of the act. He appealed on the basis that congress only had power to regulate activities that had an effect on the interstate commerce. The activity in question had no connection to this.

Procedural history: the lower court convicted him; the court of Appeals reversed these findings on the basis that the regulation fell out of the ambit of congress.

Issue: does congress possess the power to regulate those activities that don’t affect the interstate commerce?

Holding: the court found that congress lacked such power. The activities it regulates have to have a substantial effect on the commerce between states

Judgment: the findings and the judgment of the court of appeals was affirmed. Congress lacked the power to regulate the activity in question

Reasoning: the commerce power allows congress only to regulate those activities that have a substantial effect on interstate commerce. There was no evidence or law provision that indicated the manner in which the activity in this case was going to affect commerce between the states.

New York V. United States, 505 U.S. 144(1992)

Facts: the low-Level Radioactive Waste Policy Amendments Act (1985) enacted by congress obligated the states to either make provisions for the disposal of the radioactive waste or take title to such waste within its borders. New York however argued that this was a violation of the sovereignty of states provided for under the tenth amendment of the United States constitution which should not be allowed.

Procedural history: in the federal district court, the complaints were dismissed; this was affirmed by the court of appeals, which led to this appeal.

Issue: congress lacks the power to force states to adhere to any state regulations. Did this apply in this case too?

Holding: the court ruled that this provision was a violation of the tenth amendment of the constitution as it amounted to coercion of the states.

Judgment: The Supreme Court granted certiorari, reversed in part and affirmed in part.

Reasoning: there is a great need to adhere to the separation of power doctrine to promote and ensure effectiveness. There is need to illuminate and examine the regulations ordered by congress and make them accountable.

Printz v. United States, 521 U.S. 898 (1997)

Facts: the Brady handgun violence prevention act interim provisions compelled the state officers to implement federal law that obligated them to perform background checks and other related activities on those who want to buy handguns. Printz and other key enforcement officers of the law brought a petition arguing this was unconstitutional.

Procedural history: the district court ruled in the favour of the petitioners but this was reversed in the court of appeal, hence this appeal.

Issue: was the mandate placed upon state officers to carry out the background checks and other related activities constitution?

Holding: the federal government lacked the authority to command the state officers to perform any of these acts.

Judgment: the court of appeals findings were reversed. The history of the Precedents of the United States does not reveal any authority granted to congress to require the executives of state to implement the federal statutes

Reasoning: there are no constitutional provisions empowering congress to commandeer state officers to enforce the regulatory programs initiated by congress directly.