United States v. Morrison (2000) is a Supreme Court case that struck down part of the Violence Against Women Act of 1994, ruling that gender-motivated violence is not economic activity, so Congress cannot regulate it under the Commerce Clause. It marks a shift toward limiting national power and favoring the states.
In 1994, Congress passed the Violence Against Women Act (VAWA), which let victims of gender-motivated violence sue their attackers in federal court. Congress justified this under the Commerce Clause, arguing that violence against women hurts the national economy. In United States v. Morrison (2000), the Supreme Court said no. Gender-motivated violence is not an economic activity, and Congress can't stretch the Commerce Clause to cover it just by pointing to indirect economic effects. The Court also rejected the Fourteenth Amendment as a backup justification, because that amendment restrains state governments, not private individuals.
For AP Gov, Morrison is an illustrative example in Topic 1.8 of how Supreme Court interpretation shifts the balance of power in federalism. After decades of the Court reading the Commerce Clause broadly (think Gibbons v. Ogden in 1824 and the New Deal era cases), Morrison continued the trend started by United States v. Lopez (1995) of drawing a line. If everything with a ripple effect on the economy counted as interstate commerce, the federal government would have unlimited power and the states would have nothing left. Morrison reinforced that some things, like local criminal law, belong to the states.
Morrison lives in Unit 1: Foundations of American Democracy, Topic 1.8 (Constitutional Interpretations of Federalism). It directly supports learning objective 1.8.A, which asks you to explain how the balance of power between national and state governments has changed over time based on Supreme Court interpretations. The CED's essential knowledge says it plainly: the Commerce Clause gives Congress power over interstate commerce, but Supreme Court interpretations can influence the extent of this power. Morrison is one of the clearest modern examples of the Court shrinking that power. It pairs with McCulloch v. Maryland (expanding national power) and United States v. Lopez (limiting it) to show that federalism is not a fixed line. It's a tug-of-war, and the Court is the referee who keeps moving the rope.
Keep studying AP® Gov Unit 1
Commerce Clause (Unit 1)
Morrison is fundamentally a Commerce Clause case. The Court ruled that 'affecting the economy somehow' isn't enough. The activity Congress regulates has to actually be economic in nature, which put a real ceiling on the clause for the first time in decades.
Enumerated Powers (Unit 1)
Morrison reinforces the core logic of enumerated powers. Congress only has the powers the Constitution lists, and if the Commerce Clause covered everything, the list would be meaningless. The Court used Morrison to keep that list a real limit.
Dual Federalism (Unit 1)
Morrison reflects a revival of dual federalism thinking, the idea that national and state governments each control separate spheres. Criminal law and family law sit in the states' sphere, and the Court refused to let Congress reach into it.
Cooperative Federalism (Unit 1)
Morrison pushes against the cooperative federalism model that dominated from the New Deal through the 1980s, where federal and state power blended together. Cases like Lopez and Morrison signal the Court trying to redraw boundaries that cooperative federalism had blurred.
Morrison is an illustrative example, not one of the 15 required Supreme Court cases, so the exam won't demand it by name. But it's a perfect piece of evidence to bring yourself. Multiple-choice questions in this style ask what the Court decided (it struck down part of VAWA), why (gender-motivated violence isn't economic activity under the Commerce Clause), and which principle it reinforced (limited national power and federalism). One common stem asks you to trace Commerce Clause interpretation from Gibbons v. Ogden (1824) to Morrison (2000), so know the arc: broad reading, broader New Deal reading, then Lopez and Morrison pulling it back. On the SCOTUS comparison FRQ, if the required case is United States v. Lopez, Morrison is a strong reinforcing example showing Lopez wasn't a one-off. In the argument essay, it's solid evidence for any claim that federalism still limits congressional power.
Both cases limit the Commerce Clause, but Lopez is the required case and came first. Lopez struck down the Gun-Free School Zones Act because possessing a gun near a school isn't economic activity. Morrison applied the same logic five years later to strike down VAWA's civil remedy for gender-motivated violence. Think of Morrison as the Court saying 'we meant it' after Lopez. On the exam, Lopez is the case you must know cold; Morrison is the bonus evidence that strengthens a Lopez-based argument.
United States v. Morrison (2000) struck down the part of the Violence Against Women Act of 1994 that let victims of gender-motivated violence sue in federal court.
The Court ruled that gender-motivated violence is not economic activity, so Congress cannot regulate it under the Commerce Clause, even if it indirectly affects the economy.
The Court also rejected the Fourteenth Amendment justification because that amendment limits state governments, not private individuals.
Morrison shifted the balance of power toward the states, supporting LO 1.8.A's point that Supreme Court interpretation changes the reach of national power over time.
Morrison extended the logic of United States v. Lopez (1995), confirming that the Commerce Clause has real limits after decades of broad interpretation.
Crime and family law remained matters for the states, reinforcing the principle of enumerated and limited national power.
The Supreme Court struck down the civil remedy provision of the Violence Against Women Act of 1994, ruling 5-4 that Congress lacked the power under the Commerce Clause to regulate gender-motivated violence because it is not economic activity.
No. It's an illustrative example in Topic 1.8, not one of the 15 required Supreme Court cases. The required Commerce Clause case is United States v. Lopez (1995), but Morrison makes excellent supporting evidence.
Both limited the Commerce Clause, but Lopez (1995) struck down a federal gun-free school zones law while Morrison (2000) struck down part of the Violence Against Women Act. Morrison confirmed that Lopez's limit on congressional power was a lasting shift, not a fluke.
No. It only struck down the provision allowing victims to sue attackers in federal court. Other parts of VAWA, like federal grant funding for state and local programs, stayed in place.
The Fourteenth Amendment's protections apply against state governments, not private individuals. Since VAWA's civil remedy targeted private attackers rather than state actions, the Court ruled Congress's Fourteenth Amendment enforcement power didn't cover it.
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