United States v. Morrison
United States Supreme Court
529 U.S. 598 (2000)
In 1994, Congress passed the Violence Against Women Act (VAWA), which contained a provision for a federal civil remedy for victims of gender-based violence, even when victims did not file criminal charges. That same year, Christy Brzonkala, a female student at Virginia Tech University, was allegedly assaulted and raped by Antonio Morrison (defendant) and James Crawford. Morrison was temporarily suspended from school, but a state grand jury did not find enough evidence to indict him. Brzonkala and the United States government (plaintiffs) brought suit against Morrison, Crawford, and Virginia Tech under the VAWA in federal district court. Morrison challenged the VAWA as an unconstitutional exercise of Congress’s Commerce Clause powers. The district court held that Congress lacked authority to enact the VAWA, but a three-judge panel of the Fourth Circuit Court of Appeals reversed. The Fourth Circuit then reheard the case and upheld the district court’s decision that Congress lacked authority. Brzonkala and the United States appealed to the United States Supreme Court.
Rule of Law
Holding and Reasoning (Rehnquist, C.J.)
Concurrence (Thomas, J.)
Dissent (Souter, J.)
Dissent (Breyer, J.)
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