United States v. Morrison
Supreme Court
529 U.S. 598 (2000)
The 1994 Violence Against Women Act (VAWA) created a federal civil remedy for victims of gender-based violence, without regard to whether criminal charges were filed. Christy Brzonkala, a Virginia Tech student, was allegedly assaulted and raped by Antonio Morrison (defendant) and James Crawford; a state grand jury declined to indict, and Brzonkala and the United States sued Morrison, Crawford, and Virginia Tech under VAWA in federal court. Morrison challenged VAWA as exceeding Congress's Commerce Clause authority; the district court agreed, a Fourth Circuit panel initially reversed, but the full Fourth Circuit sitting en banc restored the district court's ruling that Congress lacked authority, and the case reached the Supreme Court.
Whether Congress may, under its Commerce Clause powers, create civil remedies for victims of gender-based violence to sue their attackers in civil court, and whether Congress may regulate the discriminatory conduct of private actors under Section 5 of the Fourteenth Amendment.