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United States v. Morrison

United States Supreme Court
529 U.S. 598, 120 S. Ct. 1740, 146 L. Ed. 2D 658 (2000)

Written by Megan Petersen, JD

Facts

In 1994, Congress passed the Violence Against Women Act (VAWA), which created a federal civil remedy for victims of gender-based violence, allowing such victims to assert civil suits for damages independent of any criminal prosecutions. The same year, Christy Brzonkala (plaintiff), a freshman at Virginia Tech University (defendant), was allegedly assaulted and raped by football players Antonio Morrison and James Crawford (defendants). Morrison was temporarily suspended from school, but his punishment was subsequently set aside. Brzonkala filed a civil suit against Morrison, Crawford, and Virginia Tech University under VAWA in federal district court. Morrison argued that VAWA’s civil-remedy provision was unconstitutional because Congress lacked authority to enact a civil remedy for gender-based violence. The United States government intervened to defend the provision’s constitutionality. Alongside Brzonkala, the government argued that Congress had authority to enact the civil-remedy provision under either the Commerce Clause or § 5 of the Fourteenth Amendment. The district court rejected those arguments and deemed the civil-remedy provision unconstitutional. The Fourth Circuit, sitting en banc, affirmed. The United States Supreme Court granted certiorari.

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Dissent (Souter, J.)

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