Printz v. United States

Following is the case brief for Printz v. United States, 521 U.S. 898 (1997)

Case Summary of Printz v. United States:

  • The Brady Handgun Violence Prevention Act, a federal law, called for State and local law enforcement officials to conduct background checks people seeking to buy a gun.
  • Two law enforcement officials from Montana and Arizona challenged the law on constitutional grounds.
  • The Court of Appeals found the mandatory background check constitutional.
  • The U.S. Supreme Court, however, held that it would violate the Tenth Amendment to require State and local law enforcement officials to carry out federal law.

Printz v. United States Case Brief

Statement of the Facts:

The federal Gun Control Act of 1968 was designed to limit the sale and ownership of guns.  In that law, certain people were disqualified from owning a gun, including convicted felons, fugitives, people who are mentally ill, and non-citizens who had no legal status in the country. In 1993, the Brady Handgun Violence Prevention Act required that background checks be completed to ensure that guns were not falling into the hands of those disqualified from possessing a gun.

The Brady Act’s background check system was to go into effect in 1998.  In the interim, the Brady Act called for gun purchasers to fill out a personal information form.  Gun distributors were mandated to provide that Brady form to local law enforcement.  Then, law enforcement officials had five days to determine, through a reasonable effort, that the potential gun purchaser was qualified to own a gun under the Gun Control Act.

Two chief law enforcement officers from Montana and Arizona (Jay Printz being one of the two) challenged the Brady Act’s interim procedure, arguing that it forced state officials to enforce federal law.

Procedural History:

  • The District Court held that the state officers could not be constitutionally required to perform the background checks.
  • The Ninth Circuit Court of Appeals reversed, holding that the mandatory checks were constitutional.
  • The U.S. Supreme Court granted certiorari.

Issue and Holding:

Is it constitutional for a federal law to require that State and local law enforcement officers conduct background checks on gun purchasers?  No.

Judgment:

The Ninth Circuit decision is reversed.

Rule of Law or Legal Principle Applied:

It is a violation of the Constitution for a federal law to direct State and local law enforcement officers to administer a federal regulatory scheme of conducting background checks on gun purchasers.

Reasoning:

The majority opinion focused on history, the Constitution’s structure, and Court precedent to reach its decision.

With regard to history, there is no evidence through the history of federal laws that the Federal Government commanded the executive branches of States to carry out Congress’s bidding.  It is true that the Federal Government has commanded State judges to enforce Federal laws.  That, however, is inherent in the hierarchy of courts that goes from State to Federal.

With regard to the Constitution’s structure, it is clear that our system of government is based on “dual sovereignty,” in which federalism provides a distinction between the powers of the State versus the power of the Federal Government.  It would violate federalism principles to give the Federal Government complete control of State law enforcement, at no cost to the Federal Government.

Finally, with regard to Court precedent, Court decisions like New York v. U.S., stand for the proposition that the Federal Government may not compel the States to administer a federal regulatory program.

Concurring and Dissenting Opinions:

Concurring Opinion (O’Connor):

The Brady Act violates the Tenth Amendment by forcing State and local officials to perform background checks pursuant to federal law.

Concurring Opinion (Thomas):

It should be emphasized that the Tenth Amendment affirms the principle that the Federal Government is one of limited, enumerated powers.  Here, the Federal Government acted outside of its authority.

Dissenting Opinion (Stevens):

The ability of the Federal Government, under its powers from the Constitution, to impose affirmative obligations on executive and judicial officers is supported by the text and history of the Constitution, and Court precedent.  Congress can regulate commerce and do what is necessary and proper to enforce federal law.  Thus, there is ample authority for the Brady Act’s enforcement by State and local authorities.  History, back to Hamilton’s Federalist No. 27 also supports the Federal Government’s power here.  Finally, the precedent cited by the Court is not applicable to the present case.

Dissenting Opinion (Souter):

Hamilton’s Federalist No. 27 is the most straightforward authority for what the Federal Government did in this case.  The majority’s attempt to claim that Federalist No. 27 is not applicable here is unpersuasive.

Dissenting Opinion (Breyer):

Other nations struggle with the conflict between central versus local control, and those other nations reject the approach posited by the majority.

Significance:

Printz v. United States stands for the proposition that Congress cannot commandeer a State’s executive branch for federal purposes.  This case, however, had little practical value because most State and local officials voluntarily complied with the Brady Act’s background check provisions.  Also, once the federal background check system was in place in 1998, a year after this decision was handed down, the issue became moot.

Student Resources:

Full text of Opinion

Listen to the Oral Argument

 

 

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