Lesson 21: What is the Role of Congress in American Constitutional Democracy?
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Schechter Poultry Corporation v. United States (1935)
Facts of the case:
Section 3 of the National Industrial Recovery Act empowered the president to implement industrial codes to regulate weekly employment hours, wages, and minimum ages of employees. The codes had standing as penal statutes.
Case Question:
Did Congress unconstitutionally delegate legislative power to the president?
Case Conclusion:
The Court held that Section 3 was "without precedent" and violated the Constitution. The law did not establish rules or standards to evaluate industrial activity. In other words, it did not make codes, but simply empowered the president to do so. A unanimous Court found this to be an unconstitutional delegation of legislative authority.
Citation:
The Oyez Project, Schechter Poultry Corp. v. United States, 295 U.S. 495 (1935)
Link to case: https://www.oyez.org/cases/1900-1940/295us495
United States v. Butler (1936)
Facts of the case:
As part of the 1933 Agricultural Adjustment Act, Congress implemented a processing tax on agricultural commodities, from which funds would be redistributed to farmers who promised to reduce their acreage. The act intended to solve the crisis in agricultural commodity prices which was causing many farmers to go under.
Case Question:
Did Congress exceed its constitutional taxing and spending powers with the act?
Case Conclusion:
The Court found the act unconstitutional because it attempted to regulate and control agricultural production, an arena reserved to the states. Even though Congress does have the power to tax and appropriate funds, argued Justice Roberts, in this case those activities were "but means to an unconstitutional end," and violated the Tenth Amendment.
Citation:
The Oyez Project, United States v. Butler, 297 U.S. 1 (1936)
Link to case: https://www.oyez.org/cases/1900-1940/297us1
Wickard v. Filburn (1942)
Facts of the case:
Filburn was a small farmer in Ohio. He was given a wheat acreage allotment of 11.1 acres under a Department of Agriculture directive which authorized the government to set production quotas for wheat. Filburn harvested nearly 12 acres of wheat above his allotment. He claimed that he wanted the wheat for use on his farm, including feed for his poultry and livestock. Filburn was penalized. He argued that the excess wheat was unrelated to commerce since he grew it for his own use.
Case Question:
Is the amendment subjecting Filburn to acreage restrictions in violation of the Constitution because Congress has no power to regulate activities local in nature?
Case Conclusion:
According to Filburn, the act regulated production and consumption, which are local in character. The rule laid down by Justice Jackson is that even if an activity is local and not regarded as commerce, "it may still, whatever its nature, be reached by Congress if it exerts a substantial economic effect on interstate commerce, and this irrespective of whether such effect is what might at some earlier time have been defined as 'direct' or 'indirect.'"
Citation:
The Oyez Project, Wickard v. Filburn, 317 U.S. 111 (1942)
Link to case: https://www.oyez.org/cases/1940-1955/317us111
Gomillion v. Lightfoot (1960)
Facts of the case:
An act of the Alabama legislature re-drew the electoral district boundaries of Tuskegee, replacing what had been a region with a square shape with a twenty-eight sided figure. The effect of the new district was to exclude essentially all blacks from the city limits of Tuskegee and place them in a district where no whites lived.
Case Question:
Did the redrawing of Tuskegee's electoral district boundaries violate the Fifteenth Amendment of the Constitution, which prevents the United States or any individual state from denying a citizen the right to vote on account of race, color, or previous condition of servitude?
Case Conclusion:
Yes. The unanimous Court held that Act 140 of the Alabama legislature violated the Fifteenth Amendment. Justice Frankfurter admitted that states are insulated from judicial review when they exercise power "wholly within the domain of state interest." However, in this case, Alabama's representatives were unable to identify "any countervailing municipal function" which the act was designed to serve. It was clear to the Court that the irregularly shaped district was drawn with only one purpose in mind, namely, to deprive blacks of political power.
Citation:
The Oyez Project, Gomillion v. Lightfoot, 364 U.S. 339 (1960)
Link to case: http://oyez.org/cases/1960-1969/1960/1960_32
Baker v. Carr (1962)
Facts of the case:
Charles W. Baker and other Tennessee citizens alleged that a 1901 law designed to apportion the seats for the state's general assembly was virtually ignored. Baker's suit detailed how Tennessee's reapportionment efforts ignored significant economic growth and population shifts within the state.
Case Question:
Did the Supreme Court have jurisdiction over questions of legislative apportionment?
Case Conclusion:
Yes. In an opinion which explored the nature of "political questions" and the appropriateness of Court action in them, the Court held that there were no such questions to be answered in this case and that legislative apportionment was a justiciable issue. In his opinion, Justice Brennan provided past examples in which the Court had intervened to correct constitutional violations in matters pertaining to state administration and the officers through whom state affairs are conducted. Brennan concluded that the Fourteenth Amendment equal protection issues which Baker and others raised in this case merited judicial evaluation.
Citation:
The Oyez Project, Baker v. Carr, 369 U.S. 186 (1962)
Link to case: http://oyez.org/cases/1960-1969/1960/1960_6
Heart of Atlanta Motel v. United States (1964)
Facts of the 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.
Case 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?
Case Conclusion:
No. The Court held that the Commerce Clause allowed Congress to regulate local incidents of commerce, and that the Civil Right Act of 1964 passed constitutional muster. The Court noted that the applicability of Title II was "carefully limited to enterprises having a direct and substantial relation to the interstate flow of goods and people..." The Court thus concluded that places of public accommodation had no "right" to select guests as they saw fit, free from governmental regulation.
Citation:
The Oyez Project, Heart of Atlanta Motel v. U.S., 379 U.S. 241 (1964)
Link to case: http://oyez.org/cases/1960-1969/1964/1964_515
South Dakota v. Dole (1987)
Facts of the 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.
Case Question:
Did Congress exceed its spending powers, or 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?
Case Conclusion:
No. In a 7-to-2 decision, the Court held that Congress, acting indirectly to encourage uniformity in states' drinking ages, was within constitutional bounds. The Court found that the legislation was in pursuit of "the general welfare," and that the means chosen to do so were reasonable. The Court also held that 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.
Citation:
The Oyez Project, South Dakota v. Dole, 483 U.S. 203 (1987)
Link to case: http://oyez.org/cases/1980-1989/1986/1986_86_260
U.S. Term Limits, Inc. v. Thornton (1995)
Facts of the case:
On November 3, 1992, Arkansas voters adopted Amendment 73 to their State Constitution. The "Term Limitation Amendment," in addition to limiting terms of elected officials within the Arkansas state government, also provided that any person who served three or more terms as a member of the United States House of Representatives from Arkansas would be ineligible for re-election as a U.S. Representative from Arkansas. Similarly, the Amendment provided that any person who served two or more terms as a member of the United States Senate from Arkansas would be ineligible for re-election as a U.S. Senator from Arkansas.
Case Question:
Can states alter those qualifications for the U.S. Congress that are specifically enumerated in the Constitution?
Case Conclusion:
No. The Constitution prohibits States from adopting Congressional qualifications in addition to those enumerated in the Constitution. A state congressional term limits amendment is unconstitutional if it has the likely effect of handicapping a class of candidates and "has the sole purpose of creating additional qualifications indirectly." Furthermore, "allowing individual States to craft their own congressional qualifications would erode the structure designed by the Framers to form a 'more perfect Union.'"
Citation:
The Oyez Project, U.S. Term Limits v. Thornton, 514 U.S. 779 (1995)
Link to case: http://oyez.org/cases/1990-1999/1994/1994_93_1456
United States v. Lopez (1995)
Facts of the case:
Alfonzo Lopez, a twelfth grade high school student, carried a concealed weapon into his San Antonio, Texas high school. He was charged under Texas law with firearm possession on school premises. The next day, the state charges were dismissed after 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.
Case 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?
Case Conclusion:
Yes. 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.
Citation:
The Oyez Project, United States v. Lopez, 514 U.S. 549 (1995)
Link to case: http://oyez.org/cases/1990-1999/1994/1994_93_1260
Gonzales v. Raich (2005)
Facts of the case:
In 1996 California voters passed the Compassionate Use Act, legalizing marijuana for medical use. California's law conflicted with the federal Controlled Substances Act (CSA), which banned possession of marijuana. After the Drug Enforcement Administration (DEA) seized doctor-prescribed marijuana from a patient's home, a group of medical marijuana users sued the DEA and U.S. Attorney General John Ashcroft in federal district court. The medical marijuana users argued the Controlled Substances Act--which Congress passed using its constitutional power to regulate interstate commerce--exceeded Congress's 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. Relying on two U.S. Supreme Court decisions that narrowed Congress's Commerce Clause power--U.S. v. Lopez (1995) and U.S. v. Morrison (2000)--the Ninth Circuit ruled using medical marijuana did not "substantially affect" interstate commerce and therefore could not be regulated by Congress.
Case Question:
Does the Controlled Substances Act (21 U.S.C. 801) exceed Congress's power under the Commerce Clause as applied to the intrastate cultivation and possession of marijuana for medical use?
Case Conclusion:
No. In a 6-3 opinion delivered by Justice John Paul Stevens, the Court held that the Commerce Clause gave Congress authority to prohibit the local cultivation and use of marijuana, despite state law to the contrary. Stevens argued that 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. The majority argued that 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. The majority distinguished the case from Lopez and Morrison. In those cases, statutes regulated non-economic activity and fell entirely outside Congress' commerce power; in this case, the Court was asked to strike down a particular application of a valid statutory scheme.
Citation:
The Oyez Project, Gonzales v. Raich, 545 U.S. 1 (2005)
Link to case: http://oyez.org/cases/2000-2009/2004/2004_03_1454
