SCOTUS Presentation - Frida Muñiz Villagran

United States v. Lopez(1995)

Frida Muñiz Villagran

United States v. Lopez (1995)

Facts

In early March of 1992, 12-grade Alfonso Lopez carried a concealed wepon to his Edison High School located in San Antonio, Texas.He was then charged under the Texas law of possession of a firearm in school premises. The state charges were later dismissed because federal agents had charged Lopez with a violation of a federal criminal statue: Gun-Free School Zones Act (1990). This act "punishes you for possessing a firearm in a place that you know or reasonably should know is within a school zone". Beacuse of this, Lopez was found guilty with a bench trial & a 6-month sentence, and 2 years supervised release.

Questions

The question for this case is:"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?"

Ruling

This possession of a firearm in a school zone is not an activity that should be repeated elsewhere & can have a substantial effect on interstate commerce. This law is a criminal statue that has no connection with Commerce or economic activity.

United States v. Morrison (2000)

Facts

In 1994, student from Virginia Polytechnic Institute (Virginia Tech) Chtisty Brzonkala, claimed that both varsity football players Antonio Morrison & James Crawford raped her.In 1995, a complaint under Virginia Tech's Sexual Assault Policy was filed by Brzonkala, against Morrison & Crawford. Morison was found guilty & sentenced to immediate suspension for 2 semesters, meanwhile, Crawford was not punished at all. An appeal was later made by the university's administrative system which allowed for Morrison's punishment to be put aside because it was founded "excessive". Brozonkala later dropped out and sued Morrison, Crawford, & Virginia Polytechnic Institute (Virginia Tech) in a Federal District Court claiming that Morrison & Crawford's attack had violated the 42 USC section 13981, part of the Violence Against Women Act (VAWA) (1994). This act provides federal civil remedy for victims of gender-motivated violence.By dismissing this complaint, District Court saw that Congress actually lacked authority to enact section 13981 under Commerce Clause or the 14th Amendmant. Congress had also identified them as the sources of federal authority for such.Following this, Court of appeals had affirmed.

Questions

The question for this case is:"Does Congress have the authority to enact the Violence Against Women Act of 1994 under either the Commerce Clause or Fourteenth Amendment?"

Ruling

May 15th of 2000, the United States Supreme Court decided that some sections of the Violence Against Women Act (VAWA) (1994) are unconstitutional because it exceeded power given to Congress under the Commerce Clause & the 14th Amendment.

Constitutional ClausePresent in both cases:

Commerce Clause

Allowes for Congress to have broad power to regulate interstate Commerce & restrict states from impairing interstate Commerce.

Constitutional Clause

Court claimed that Gun-Free School Zone Act (1990) exceeded Congress's power to regulate interstate Commerce because of the lack of substantial connection of interstating commerce.Because of this, Court shifted their approach to the Commerce Clause & limmited federal overreach in regulation of local activities.

United States v. Lopez (1995)

Court took down a section of the Violence Against Women Act (VAWA) (1994) where it was allowed for victims to sue their perpetrators in a Federal Court.As a result, Court decided that it was an unvalid exersise by the power Congress held upon the Commerce Clause because they didn't have effect on the Interstate Commerce.

united states v. Morrison (2000)

Both cases had the Supreme Court limit Congress's power for the Commerce Clause. This was done by ruling such federal laws used in each case, that exceeded the constitutional boundaries.

similarity

Similarity

United States v. Lopez (1995)

Congress only rewrote and made a connection to the Interstate Commerce clearer the Gun-Free School Zones Act (1990).

United States v. Morrison (2000)

The invalidation of Section 13981 of Violence Against Women Act (VAWA) (1994) where it provided victims the right to sue their perpetrators in Federal Court.

Long-term impact

Thank You

Frida Muñiz Villagran