United States v. Morrison
| United States v. Morrison | |
|---|---|
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| Argued January 11, 2000 Decided May 15, 2000 |
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| Full case name | United States v. Antonio J. Morrison et al. and Christy Brzonkala v. Antonio J. Morrison et al. |
| Docket nos. |
99-5 99-29 |
| Citations | 529 U.S. 598 (more)
120 S. Ct. 1740; 146 L. Ed. 2d 658; 2000 U.S. LEXIS 3422; 68 U.S.L.W. 4351; 82 Fair Empl. Prac. Cas. (ily Journal DAR 5061; 2000 Colo. J. C.A.R. 2583; 13 Fla. L. Weekly Fed. S 287
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| Argument | Oral argument |
| Prior history | Brzonkala v. Va. Polytechnic Inst. & State Univ., 935 F. Supp. 779 (W.D. Va. 1996), aff'd, 169 F.3d 820 (4th Cir. 1999), cert. granted sub nom. United States v. Morrison, 527 U.S. 1068 (1999). |
| Holding | |
| The Violence Against Women Act of 1994, 42 U.S.C. § 13981, is unconstitutional as exceeding congressional power under the Commerce Clause and under section 5 of the Fourteenth Amendment to the Constitution. | |
| Court membership | |
| Case opinions | |
| Majority | Rehnquist, joined by O'Connor, Scalia, Kennedy, Thomas |
| Concurrence | Thomas |
| Dissent | Souter, joined by Stevens, Ginsburg, Breyer |
| Dissent | Breyer, joined by Stevens; Souter, Ginsburg (Part 1-A) |
| Laws applied | |
| U.S. Const. Art. I, § 8, cl. 3; U.S. Const. Amend. XIV; 42 U.S.C. § 13981. | |
United States v. Morrison, 529 U.S. 598 (2000), is a United States Supreme Court decision which held that parts of the Violence Against Women Act of 1994 were unconstitutional because they exceeded congressional power under the Commerce Clause and under section 5 of the Fourteenth Amendment to the Constitution.
In 1994, the United States Congress passed the Violence Against Women Act, which contained a provision at 42 U.S.C. § 13981 for a federal civil remedy to victims of gender-based violence, even if no criminal charges had been filed against the alleged perpetrator of that violence.
That fall, at Virginia Tech, freshman student Christy Brzonkala was assaulted and raped repeatedly by fellow students Antonio Morrison and James Crawford. During the school-conducted hearing on her complaint, Morrison admitted having sexual contact with her despite the fact that she had twice told him "no." College proceedings failed to punish Crawford, but initially punished Morrison with a suspension (punishment later struck down by the administration). A state grand jury did not find sufficient evidence to charge either man with a crime. Brzonkala then filed suit under the Violence Against Women Act.
The United States District Court for the Western District of Virginia held that Congress lacked authority to enact 42 U.S.C. § 13981. A three-judge panel of the Court of Appeals for the Fourth Circuit reversed the decision 2–1. The Fourth Circuit reheard the case en banc and reversed the panel, upholding the district court.
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