Federalism & Supreme Court! Chapter 3 McCulloch V. Maryland (1819) Background of case: 2nd BUS was created in 1816, state of Maryland tried to tax it out of existence in 1818, chief of the bank refused to pay tax (McCulloch) 2 Constitutional Questions: Congress have authority to set up bank? Maryland law unconstitutionally interfering with Congressional Powers (A1, sec. 8 clauses 1 & 18)? Decision: 7-0 in favor of McCulloch! Why? the Court held that Congress had the power to incorporate the bank and that Maryland could not tax instruments of the national government employed in the execution of constitutional powers Congress possessed unenumerated powers not explicitly outlined in the Constitution; while the states retained the power of taxation "the constitution and the laws made in pursuance thereof are supreme. . .they control the constitution and laws of the respective states Constitutional Principle/law: Legitimized the Implied Powers (A1 S8 C1 & 18) , and Supremacy Clause (A6)! https://www.youtube.com/watch?v=8iIlVrzvCH8 Gibbons V. Ogden (1824) Background of case: NY State law gave two people exclusive rights to operate steamboat, Gibbons from NJ protested law requiring a hefty tax to operate steamboat across state lines from NJ to NY due to law! Constitutional Question: Did NY encroach on power reserved for Congress, the Regulation of Interstate Commerce? Decision: 6-0 in favor of Gibbons! Why? New York's licensing requirement for out-of-state operators was inconsistent with a congressional act regulating the coasting trade the New York law was invalid by virtue of the Supremacy Clause a clear definition of the word commerce included navigation on interstate waterways, a power reserved to and exercised by the Congress Constitutional Principle/Law: Expressed power of Commerce (Article 1 Sec. 8 Clause 3), Supremacy Clause (A6) https://www.youtube.com/watch?v=ysiFr1oLw7o Williams V. North Carolina (1945) Background of case: two separate married couples residents of NC leave their spouses, go to Nevada get divorced, get married to each other, come back to NC to live, are arrested and convicted for polygamy Constitutional Question: Can state of NC disregard full faith & credit clause of article IV? Decision: A writ of Certiorari ordering lower court to do it again! Why? The Supreme Court ruled that, “The Nevada divorces were valid, and must be given full faith and credit by North Carolina, if the travelers really were residents in Nevada when they received their divorces all 50 states (as of 1985) now permit the dissolution of marriage on at least one ‘no fault’ ground, It is unlikely that a state would go to such great lengths to preserve a marriage against the will of one spouse Constitutional Principle/Law: Full faith and credit clause must be extended if done properly meeting state requirements of residency! Loving v. Virginia 1962 Background: In 1958, two residents of Virginia, a black woman, and a white man, were married in DC. The Lovings returned to Virginia shortly thereafter. The were charged w/violating the state's antimiscegenation statute, which banned inter-racial marriages. The Lovings were found guilty and sentenced to a year in jail (the trial judge agreed to suspend the sentence if the Lovings would leave Virginia and not return for 25 years). Issue: Did Virginia's ant-miscegenation law violate the Equal Protection Clause of the Fourteenth Amendment? Decision: 9 votes for Loving, 0 vote(s) against Constitutional Principle/law: (unanimous decision) the Court held that distinctions drawn according to race were generally "odious to a free people" and were subject to "the most rigid scrutiny" under the Equal Protection Clause. The Virginia law was purely based on prejudice. Also, violation of Due Process Clause of the Fourteenth Amendment. "Under our Constitution," wrote Chief Justice Earl Warren, "the freedom to marry, or not marry, a person of another race resides with the individual, and cannot be infringed by the State." https://www.youtube.com/watch?v=IM5A8kiNA6o Heart of Atlanta Motel V. United States (1964) Background of case: Title II of the Civil Rights Act of 1964 forbade racial discrimination by places of public accommodation if their operations affected commerce, The Heart of Atlanta Motel in Atlanta, Georgia, refused to accept Black Americans and was charged with violating Title II Constitutional Question: Did Congress, in passing Title II of the 1964 Civil Rights Act, exceed its Commerce Clause powers by depriving motels, such as the Heart of Atlanta, of the right to choose their own customers? Decision: 9-0 for US Government! Why? the Commerce Clause allowed Congress to regulate local incidents of commerce, and that the Civil Right Act of 1964 passed constitutional muster the applicability of Title II was "carefully limited to enterprises having a direct and substantial relation to the interstate flow of goods and people, places of public accommodation had no "right" to select guests as they saw fit, free from governmental regulation Constitutional Principle/Law: Reinforcement of Commerce Clause (A1 S8 C3), Civil Rights Act of 1964 Title II https://www.youtube.com/watch?v=pXGbebNMzkQ South Dakota V. Dole (1987) Background of case: In 1984, Congress enacted legislation ordering the Secretary of Transportation to withhold five percent of federal highway funds from states that did not adopt a 21-year-old minimum drinking age. South Dakota, a state that permitted persons 19 years of age to purchase alcohol, challenged the law. Constitutional Question: Did Congress exceed its spending powers? violate the Twenty-first Amendment, by passing legislation conditioning the award of federal highway funds on the states' adoption of a uniform minimum drinking age? Decision: 7-2 for Dole! Why? the Court held that Congress, acting indirectly to encourage uniformity in states' drinking ages, was within constitutional bounds, the legislation was in pursuit of "the general welfare," and that the means chosen to do so were reasonable the Twenty-first Amendment's limitations on spending power were not prohibitions on congressional attempts to achieve federal objectives indirectly. The five percent loss of highway funds was not unduly coercive! Constitutional Principle/Law: It upheld Congress’s power of spending in the area of “General Welfare” and did not see it as abusing since 5% not coercive! https://www.youtube.com/watch?v=yNqfW3StnGM Puerto Rico V. Brandstad (1987) Background of case: Ronald Calder was a native of Iowa working in Puerto Rico, He was charged with first degree murder and attempted murder. After posting bail, he fled to his home state. Puerto Rico submitted a petition to Branstad, Iowa's governor at the time, to extradite Calder for court proceedings. Branstad refused. Constitutional Question: Do federal courts have the power to order governors to fulfill obligations under the Constitution's Extradition Clause in Article IV, Section 2? Decision: 9-0 for Puerto Rico! Why? The Court overturned its decision in Kentucky v. Dennison (1861) which had rendered federal courts powerless to enforce the Extradition Clause (Article IV). The unanimous Court concluded that the precedent in Kentucky was "the product of another age" and "fundamentally incompatible with more than a century of constitutional development.“ Constitutional Principle/Law: It upheld Article IV Extradition Clause! United States V. Lopez (1995) Background of case: a high school student, carried a concealed weapon into his San Antonio, Texas high school, charged under Texas law with firearm federal agents charged Lopez with violating a federal criminal statute, the Gun-Free School Zones Act of 1990. The act forbids "any individual knowingly to possess a firearm at a place that [he] knows...is a school zone." Lopez was found guilty following a bench trial and sentenced to six months' imprisonment and two years' supervised release. Constitutional Question: Is the 1990 Gun-Free School Zones Act, forbidding individuals from knowingly carrying a gun in a school zone, unconstitutional because it exceeds the power of Congress to legislate under the Commerce Clause? Decision: 5-4 for Lopez! Why? The possession of a gun in a local school zone is not an economic activity that might, through repetition elsewhere, have a substantial effect on interstate commerce. The law is a criminal statute that has nothing to do with "commerce" or any sort of economic activity. Constitutional Principle/Law: It reversed the increase of congressional power under the Commerce clause https://www.youtube.com/watch?v=78aE9SlyEOA Gonzalez V. Raich (2005) Background of case: California CUA act, legalizing marijuana for medical use conflicted with the federal Controlled Substances Act (CSA), which banned possession of marijuana; medical marijuana users argued the CSA - which Congress passed using its constitutional power to regulate interstate commerce - exceeded Congress' commerce clause power. The district court ruled against the group; the Ninth Circuit Court of Appeals reversed and ruled the CSA unconstitutional as it applied to intrastate (within a state) medical marijuana use; the Ninth Circuit ruled using medical marijuana did not "substantially affect" interstate commerce and therefore could not be regulated by Congress. Constitutional Question: Does the Controlled Substances Act (21 U.S.C. 801) exceed Congress' power under the commerce clause as applied to the intrastate cultivation and possession of marijuana for medical use? Decision: 6-3 for Gonzalez! Why? the commerce clause gave Congress authority to prohibit the local cultivation and use of marijuana, the Court's precedent "firmly established" Congress' commerce clause power to regulate purely local activities that are part of a "class of activities" with a substantial effect on interstate commerce; Congress could ban local marijuana use because it was part of such a "class of activities": the national marijuana market. Local use affected supply and demand in the national marijuana market, making the regulation of intrastate use "essential" to regulating the drug's national market Constitutional Principle/Law: Reestablished congressional power of Commerce if part of national market! https://www.youtube.com/watch?v=wUBeWz8wDGw Gonzalez V. Oregon (2006) Background of case: Oregon enacted the Death with Dignity Act, authorizing physicians to prescribe lethal doses of controlled substances to terminally ill patients. Attorney General of US declared in 2001 that physician-assisted suicide violated the Controlled Substances Act of 1970 (CSA) & threatened to revoke the medical licenses of physicians who took part in the practice. Oregon sued Ashcroft in federal district court. That court and, later the Ninth Circuit, held Ashcroft's directive illegal. The courts held that the CSA did not authorize the attorney general to regulate physician-assisted suicide, which was the sort of medical matter historically entrusted to the states. Constitutional Question: Did the Controlled Substances Act authorize the attorney general to ban the use of controlled substances for physician-assisted suicide in Oregon? Decision: 6-3 for Oregon! Why? No. Congress intended the CSA to prevent doctors only from engaging in illicit drug dealing, not to define general standards of state medical practice. Moreover, the CSA did not authorize Attorney General John Ashcroft to declare a medical practice authorized under state law to be illegitimate. Constitutional Principle/Law: It pushed back against the expansion of Federal powers in areas under article IV & 10th amendment reserved for the states to practice! https://www.youtube.com/watch?v=_F-525sCzhE Windsor V. United States (2013) Background of case: The Defense of Marriage Act (DOMA), defined marriage on federal level between one man and one woman. Edith Windsor the widow and sole executor of the estate of her late spouse, Thea Clara Spyer, who died in 2009. The two were married in Toronto, Canada, in 2007, and their marriage was recognized by New York state law. Thea Syper left her estate to her spouse, and because their marriage was not recognized by federal law, the government imposed $363,000 in taxes. Had their marriage been recognized, the estate would have qualified for a marital exemption, and no taxes would have been imposed; On November 9, 2010 Windsor filed suit in district court seeking a declaration that the Defense of Marriage Act was unconstitutional; President & AG refused to defend DOMA, however, House of Representative decided to do it and field motion to dismiss case. Constitutional Question: Does the Defense of Marriage Act, which defines the term “marriage” under federal law as a “legal union between one man and one woman” deprive same-sex couples who are legally married under state laws of their Fifth Amendment rights to equal protection under federal law? Decision: 5-4 for Windsor! Under article IV states have the authority to define marital relationships and that DOMA goes against legislative and historical precedent by undermining that authority; effect of DOMA is to impose a “disadvantage, a separate status, and so a stigma” on same-sex couples in violation of the Fifth Amendment’s guarantee of equal protection Constitutional Principle/Law: Under federalism DOMA infringes on rights reserved for state to decide ! https://www.youtube.com/watch?v=t7b6W6OLGJ0