Which case limited Congress's power over interstate commerce by striking down parts of the Violence Against Women Act?

Which case limited Congress's power over interstate commerce by striking down parts of the Violence Against Women Act?

• A. Gibbons v. Ogden
• B. Gonzales v. Raich
• C. United States v. Morrison
• D. Heart of Atlanta Motel v. United States

Answer: (C)

The key idea being tested is the limits of Congress’s power under the Commerce Clause when regulating private, non-economic conduct. United States v. Morrison holds that Congress exceeded its authority by using the Violence Against Women Act’s civil remedy provision to reach gender-based violence. The Court reasoned that private acts of violence against individuals are not an economic activity that substantially affects interstate commerce, so regulating such conduct cannot be justified as a regulation of interstate commerce. The decision also clarifies that the 14th Amendment does not provide a blanket authority for Congress to regulate private acts of violence; its enforcement power is tied more to state action and unequal treatment by the states, not to policing private behavior in general. Understanding Morrison helps you see why this is the correct pick: it marks a limit on federal reach under the Commerce Clause by focusing on the nature of the regulated activity—private, non-economic conduct with only a tenuous connection to interstate commerce—not on the fact that the law is aimed at reducing violence against women. Relating this to other cases helps place it in context. Gibbons v. Ogden is about the broad reach of the Commerce Clause to regulate navigation and commerce across states, strengthening federal power in economic activity. Heart of Atlanta Motel v. United States similarly upheld federal regulation of interstate commerce to prohibit discrimination in public accommodations. Gonzales v. Raich affirmed federal power to regulate locally grown marijuana because of its substantial effects on the broader economy. Morrison stands apart by rejecting federal authority to regulate private non-economic conduct under the Commerce Clause, which is why it’s the right choice for this question.

The key idea being tested is the limits of Congress’s power under the Commerce Clause when regulating private, non-economic conduct. United States v. Morrison holds that Congress exceeded its authority by using the Violence Against Women Act’s civil remedy provision to reach gender-based violence. The Court reasoned that private acts of violence against individuals are not an economic activity that substantially affects interstate commerce, so regulating such conduct cannot be justified as a regulation of interstate commerce. The decision also clarifies that the 14th Amendment does not provide a blanket authority for Congress to regulate private acts of violence; its enforcement power is tied more to state action and unequal treatment by the states, not to policing private behavior in general.

Understanding Morrison helps you see why this is the correct pick: it marks a limit on federal reach under the Commerce Clause by focusing on the nature of the regulated activity—private, non-economic conduct with only a tenuous connection to interstate commerce—not on the fact that the law is aimed at reducing violence against women. Relating this to other cases helps place it in context. Gibbons v. Ogden is about the broad reach of the Commerce Clause to regulate navigation and commerce across states, strengthening federal power in economic activity. Heart of Atlanta Motel v. United States similarly upheld federal regulation of interstate commerce to prohibit discrimination in public accommodations. Gonzales v. Raich affirmed federal power to regulate locally grown marijuana because of its substantial effects on the broader economy. Morrison stands apart by rejecting federal authority to regulate private non-economic conduct under the Commerce Clause, which is why it’s the right choice for this question.