Commerce Clause & Federalism

Gibbons v. Ogden

Facts: New York granted D exclusive steamboat operation rights; P operated competing ferry with federal license.

Holding: Federal navigation license preempted state-granted monopoly; Commerce Clause gives Congress broad authority.

Rule: Commerce power extends to all commercial intercourse among states; state laws yielding to valid federal legislation.

NLRB v. Jones & Laughlin Steel Corp.

Facts: Manufacturing company challenged NLRB jurisdiction over unfair labor practices at manufacturing facilities.

Holding: NLRA constitutional; labor relations have substantial effects on interstate commerce.

Rule: Commerce power extends to intrastate activities substantially affecting interstate commerce; abandoned direct/indirect distinction.

United States v. Darby (1941)

Facts: Lumber manufacturer challenged Fair Labor Standards Act minimum wage and maximum hour provisions.

Holding: FLSA constitutional; explicitly overruled Hammer v. Dagenhart.

Rule: Commerce power includes regulation of intrastate activities with substantial interstate effects; production conditions legitimate concerns.

Wickard v. Filburn (1942)

Facts: Farmer challenged wheat production quotas applied to wheat grown for personal consumption.

Holding: Regulation of wheat grown for personal use constitutional; aggregate effect on interstate commerce.

Rule: Activities with trivial impact individually may be regulated if aggregate class effect substantially impacts interstate commerce.

Heart of Atlanta Motel, Inc. v. United States

Facts: Motel refusing to accommodate Black guests challenged Civil Rights Act public accommodations provisions.

Holding: Commerce Clause authorized prohibition of racial discrimination in accommodations serving interstate travelers.

Rule: Commerce power extends to local activities substantially affecting interstate commerce, regardless of Congress's moral motives.

Katzenbach v. McClung

Facts: Restaurant refusing service to Black customers challenged Civil Rights Act's application to local restaurant.

Holding: Commerce Clause authorized regulation of restaurant purchasing substantial interstate supplies.

Rule: Restaurant's discriminatory practices affected interstate commerce by restricting market for interstate goods.

Garcia v. San Antonio Metropolitan Transit Authority

Facts: Local transit authority challenged application of federal minimum wage laws.

Holding: Fair Labor Standards Act constitutionally applied to state and local governments; overturned National League of Cities.

Rule: States' interests protected through political process, not judicially enforced immunity from generally applicable laws.

New York v. United States (1992)

Facts: Low-Level Radioactive Waste Act required states to provide disposal sites or "take title" to radioactive waste; State challenged provisions.

Holding: "Take title" provision unconstitutional; Congress cannot compel states to implement federal regulatory programs.

Rule: Federal government may incentivize state action through spending or preemption but cannot "commandeer" state legislative processes.

Printz v. United States

Facts: Local sheriffs challenged Brady Act provision requiring them to conduct background checks on handgun purchasers.

Holding: Provision unconstitutional; federal government cannot commandeer state executive officials.

Rule: Federal government cannot compel state officials to administer federal regulatory programs; violates dual sovereignty principles.

United States v. Lopez (1995)

Facts: High school student challenged Gun-Free School Zones Act criminalizing firearm possession within 1,000 feet of schools.

Holding: Act exceeded Commerce Clause authority; possession of guns near schools not economic activity substantially affecting interstate commerce.

Rule: Commerce power limited to: (1) channels of interstate commerce; (2) instrumentalities/persons/things in commerce; (3) activities substantially affecting commerce.

Reno v. Condon

Facts: SC challenged Driver's Privacy Protection Act prohibiting states from disclosing drivers' personal info without consent; claimed law violated 10th Amend.

Holding: Act constitutional; doesn't violate federalism principles.

Rule: Federal law regulating state databases valid when regulating interstate commerce in information, not commanding state regulatory apparatus.

United States v. Morrison (2000)

Facts: Woman sued attackers under Violence Against Women Act (VAWA) providing federal civil remedy for gender-motivated violence; defendants challenged constitutionality.

Holding: VAWA exceeded Congress's Commerce Clause authority.

Rule: Gender-motivated violence not economic activity; aggregate impact insufficient for Commerce Clause regulation; cannot regulate non-economic violent criminal conduct based solely on effects on interstate commerce.

Gonzales v. Raich

Facts: California residents legally growing marijuana for medical use under state law; DEA seized and destroyed plants; growers sued claiming federal CSA unconstitutional as applied.

Holding: CSA constitutional as applied; Congress can regulate intrastate marijuana cultivation.

Rule: Congress may regulate purely local activities if part of comprehensive regulation of economic activity substantially affecting interstate commerce, even if activity itself intrastate and non-commercial.

Murphy v. National Collegiate Athletic Association

Facts: NJ challenged Professional and Amateur Sports Protection Act (PASPA) prohibiting states from authorizing sports gambling.

Holding: PASPA's prohibition unconstitutional; violates anti-commandeering principle.

Rule: Congress cannot issue direct orders to state legislatures; prohibition on authorizing activity = unconstitutional commandeering of state regulatory power.

National Federation of Independent Business v. Sebelius

Facts: Congress passed Affordable Care Act requiring individuals maintain health insurance or pay penalty; expanded Medicaid, threatened to withhold existing funding from non-participating states.

Holding: Individual mandate constitutional under taxing power, not Commerce Clause; Medicaid expansion's funding threat unconstitutionally coercive.

Rule: Congress cannot regulate inactivity under Commerce Clause; taxing power permits penalties despite regulatory purpose; withholding existing funds to force state program expansion exceeds spending power.