California's Compassionate Use Act authorized the medical use of marijuana. Angel Raich and Diane Monson used or cultivated marijuana for personal medical purposes in compliance with California law, and Monson's plants were seized and destroyed by federal agents. They sought injunctive and declaratory relief, arguing that applying the federal Controlled Substances Act to their intrastate, noncommercial medical marijuana activity exceeded Congress's Commerce Clause power. The case reached the Supreme Court after the Ninth Circuit held the CSA likely unconstitutional as applied to them.
May Congress, under the Commerce Clause, prohibit the local cultivation and possession of marijuana for personal medical use as authorized by state law?
Congress may regulate purely intrastate activity if it is part of a broader regulatory scheme governing interstate commerce and if Congress could rationally conclude that leaving the intrastate activity unregulated would undercut that scheme. Under the Controlled Substances Act, Congress may reach even noncommercial, locally cultivated marijuana because of its aggregate effect on the interstate drug market.
Yes. The Court held that the Controlled Substances Act is a valid exercise of Congress's Commerce Clause authority as applied to the intrastate cultivation and possession of marijuana for personal medical use.
Relying heavily on Wickard v. Filburn, 317 U.S. 111 (1942), the Court treated respondents' conduct as economic activity because it involved the production, distribution, and consumption of a commodity for which an established interstate market exists. Congress had a rational basis to conclude that exempting locally grown medical marijuana would affect supply and demand in the national illicit marijuana market and undermine the CSA's comprehensive regulatory framework. The case was distinguished from United States v. Lopez, 514 U.S. 549 (1995), and United States v. Morrison, 529 U.S. 598 (2000), because those cases involved noneconomic activity outside a comprehensive market regulation scheme.
Justice O'Connor, joined by Chief Justice Rehnquist and in part by Justice Thomas, argued that the majority's approach erased meaningful limits on federal power and undermined states as laboratories of experimentation. Justice Thomas separately contended that homegrown marijuana for personal medical use is not interstate commerce and that the Court's reasoning stretched the Commerce Clause beyond its original meaning.
Gonzales v. Raich reaffirmed broad federal power under the Commerce Clause when regulating intrastate activity as part of a comprehensive national economic scheme, even where state law authorizes the conduct. The decision extended the logic of Wickard v. Filburn, 317 U.S. 111 (1942), and narrowed the practical reach of United States v. Lopez, 514 U.S. 549 (1995), and United States v. Morrison, 529 U.S. 598 (2000), in cases involving comprehensive market regulation. It remains a leading precedent on federal drug enforcement, federalism, and the aggregate-effects doctrine.
Wickard v. Filburn, 317 U.S. 111 (1942) |
Abstain |
United States v. Lopez, 514 U.S. 549 (1995) |
Abstain |
United States v. Morrison, 529 U.S. 598 (2000) |
Abstain |
Wickard v. Filburn, 317 U.S. 111 (1942) |
Abstain |
United States v. Lopez, 514 U.S. 549 (1995) |
Abstain |
United States v. Morrison, 529 U.S. 598 (2000) |
Abstain |
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