Following is the case brief for Gonzales v. Raich, United States Supreme Court, (2005)
Case Summary of Gonzales v. Raich:
- Raich was legally permitted to use medical marijuana and proceeded to grow her own.
- Federal agents seized and destroyed Raich’s plants.
- Raich brought an action seeking injunctive and declaratory relief preventing enforcement of the federal Comprehensive Drug Abuse Prevention and Control Act (CFA).
- The Supreme Court held that through its Commerce Clause Congress had the power to regulate the use of home-grown marijuana in a state where consumption for medical purposes is legal because in aggregate the activity could have a substantial effect on interstate commerce.
Statement of the Facts:
Congress passed the CFA in 1970 for the purpose of combating illegal drug use in the U.S. Congress then enacted the Controlled Substances Act (CSA). The act categorized illegal drugs into different categories called schedules and prevented their sale, purchase, and possession. California enacted the Compassionate Use Act in 1996. This act permitted the use of medical marijuana within states by individuals who needed it for legitimate medical purposes. Angel Raich and Diane Monson were state residents of California who legally used marijuana to treat their legitimate medical issues. Although Raich received approval from California state officials, agents of the federal government seized and destroyed her marijuana plants. In response, Raich filed suit against Alberto Gonzales, the Attorney General of the United States. Raich sought injunctive and declaratory relief prohibiting the enforcement of the federal CSA.
The court of appeals held that the CSA was an invalid exercise of Congress’s Commerce Clause power. Gonzales then appealed to the Supreme Court of the United States.
Issue and Holding:
May Congress regulate the production and use of homegrown marijuana? Yes.
Rule of Law or Legal Principle Applied:
Congress can regulate production and use of home-grown marijuana as taken in the aggregate, the activity could have a substantial economic effect on interstate commerce.
The Supreme Court reversed the lower court’s decision.
In Wickard v. Filburn, 317 U.S. 111 (1942), the Court held Congress has the power to regulate purely local activities that are part of an economic “class of activities” which have a substantial effect on interstate commerce. Here, Raich’s activity of growing marijuana for home use can be seen as having a substantial effect on interstate commerce because although illegal, there is an established interstate market for marijuana.
This case is comparable to the homegrown wheat in Wickard where Congress sought to regulate the national market for wheat through controlling homegrown commodities. Here, Congress similarly sought to regulate and eliminate the national market for illegal drugs by eliminating the home-grown varieties. As the addition of homegrown wheat to the market frustrated Congressional attempts to regulate the entire market in Wickard, Raich’s addition of homegrown marijuana to the national market, taken in the aggregate with others similarly situated, has a significant effect on Congress’s ability to eliminate the illegal marijuana market.
As a result, this Court holds the CSA is a valid exercise of Congress’s Commerce Clause power because Congress acted rationally in determining growing marijuana was an economic activity with a substantial effect on interstate commerce.
Concurring and Dissenting opinion:
Congress’s power to regulate activities having a “substantial effect” on interstate commerce is derived from the Commerce Clause and the Necessary and Proper Clause. The Necessary and Proper Clause allows Congress to do what it deems necessary to accomplish its regulatory objectives. In addition, Congress’s power under the Necessary and Proper Clause is far-reaching as Congress may regulate even those intrastate activities that have no substantial effect on interstate commerce.
Raich’s actions of growing marijuana for home use is not properly categorized as “commerce.” This is because the marijuana in question was never bought or sold, never crossed state lines and had no demonstrable effect on the marijuana market at the national level. Even when amplified by the Necessary and Proper Clause, this power has limits. Congress failed to demonstrate that regulation of medical marijuana is necessary to combat interstate drug trade as a result, their actions violate the Tenth Amendment.
The majority’s decision undermines states’ rights and federalism concerns. The decision risks opening the door for Congress to improperly regulate intrastate activity deemed essential to interstate commerce.
This case established Congressional power to regulate home-grown medical marijuana in a state where medical marijuana is legal under a state statute.