Gonzales v. Raich (2005) - Supreme Court Case

Background

• 1970: Congress enacts the Federal Controlled Substances Act (CSA) banning cultivation and use of marijuana.
• 1996: California legalizes medical marijuana for cultivation and use.
• Plaintiffs: Angel Raich and Diane Monson used doctor-prescribed marijuana in California.
  • Their marijuana use was legal under state law.
  • Federal agents seized their marijuana under the CSA.

Legal Battle

• Raich and Monson sued the U.S. Attorney General to challenge the CSA on a federal level.
• District Court: Ruled against Raich and Monson.
• Ninth Circuit Court of Appeals: Reversed decision; held that CSA is unconstitutional for intrastate (within state) medical marijuana.
• U.S. Supreme Court Question: Can Congress regulate in-state use/production of medical marijuana under its commerce authority?

Supreme Court Decision

• Majority Opinion by Justice Stevens:
  • CSA is constitutional; Congress can regulate local activities affecting interstate commerce.
  • Relied on Wickard v. Filburn precedent:
    • Congress regulated wheat production affecting interstate market.
  • Home-consumed marijuana affects interstate supply like wheat.
  • Interstate demand for marijuana means in-state marijuana may cross state lines.
  • Congress acted rationally; CSA is valid under Commerce Clause.

Concurring Opinion

• Justice Scalia:
  • Agreed with outcome but not reasoning.
  • Under Necessary and Proper Clause, Congress can regulate local activities not affecting interstate commerce directly.

Dissenting Opinions

• Justice Thomas:

  • CSA oversteps Congress's authority.
  • Raich and Monson's marijuana not commerce (not bought/sold, didn’t cross state lines).
  • Regulation not necessary for interstate drug trade combat.

• Justice O'Connor:

  • Decision infringes on states' rights.
  • Concerns over Congress's power over in-state activities deemed essential to interstate commerce regulation.

Implications

• Decision upheld federal authority to control marijuana across all states, regardless of state legalization.
• Expanded Congress's Commerce Clause authority to regulate in-state activities.
• Despite ruling, Raich continued using medical marijuana, challenging federalism stance.