Gonzales v. Raich Summary | quimbee.com
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Gonzales v. Raich Summary | quimbee.com


– [Narrator] In 2005,
medical marijuana users saw their dreams go up in smoke when the United States Supreme Court announced it’s ruling in
Gonzales versus Raich. In 1970, Congress enacted the Federal Controlled Substances Act, which bans the cultivation
and use of marijuana. 26 years later, in 1996,
California passed a law that allowed its citizens to cultivate and use marijuana for medical purposes. Angel Raich and Diane Monson
were California residents who both used doctor prescribed marijuana to treat severe medical problems. California law enforcement
agents investigating Raich and Monson, found that the
marijuana they possessed conformed to state law. But federal agents seized and destroyed their marijuana plants under the Federal
Controlled Substances Act. In an effort to legitimize
their medical marijuana use at the federal level Raich and
Monson sued Alberto Gonzales, attorney general of the United States, to challenge the Controlled Substances Act and adjoin its enforcement against them. Raich and Monson lost
in the district court. On appeal, the Ninth
Circuit Court of Appeals reversed and held that the
Controlled Substances Act is unconstitutional when applied to intrastate medical marijuana use. Which means use occurring
wholly within a state’s borders. The question for the
United States Supreme Court was whether Congress’s
authority to regulate commerce extends to the regulation
of the in-state use and production of marijuana
for medical purposes. The Court held that the
Controlled Substances Act is constitutional because
Congress has the power to regulate purely local activities that have a substantial
effect on interstate commerce. Justice Stevens writing
for the 6-3 majority, relied on the previous Supreme Court case of Wickard versus Filburn
to reach this conclusion. In Wickard, the Court held
that Congress may regulate the amount of wheat that
a farmer could produce for home consumption because
the farmer’s wheat production taken in the aggregate
had a substantial effect on interstate wheat prices. Any addition of homegrown
wheat to the overall market frustrated Congress’s attempt
to regulate the entire market. This relationship made
the regulation in Wickard a proper exercise of Congress’s
Commerce Clause authority. This case, Stevens reasoned, was similar because the Controlled Substances Act also attempts to control
the supply of a commodity. When viewed in the aggregate,
home-consumed marijuana, just like home-consumed wheat,
has a substantial effect on the interstate supply of marijuana. The Court also noted that
because there is such a high demand for marijuana
on the interstate market, the medical marijuana
grown and used in-state will inevitable end up
crossing state lines. This frustrates Congress’s
attempt to eradicate the interstate trafficking of marijuana. Therefore, the Court found that Congress had acted rationally in determining that in-state medical marijuana has a substantial effect
on interstate commerce. Therefore, the Court held
the Controlled Substances Act to be a valid exercise of Congress’s Commerce Clause authority. The Supreme Court reversed
the court of appeals and upheld the
constitutionality of the act. Justice Scalia concurred in judgment, agreeing with the outcome of the case but not with the majority’s reasoning. Scalia argued that under the
necessary and proper clause, Congress may regulate even
those in-state activities that don’t substantially
affect interstate commerce. Here, Congress adopted
a comprehensive statute that prohibits the use of marijuana. It’s therefore necessary
and proper for Congress to reach into purely local activities and prohibit them, even
if the activity doesn’t substantially affect interstate commerce. Justice Thomas wrote a dissent arguing that Congress overstepped its authority with the Controlled Substances Act. Because Raich and Monson’s cultivation and consumption of marijuana plants weren’t properly defined as commerce. He argued that their
marijuana was never bought or sold and never crossed state lines. According to Thomas,
Congress didn’t demonstrate the regulation of locally grown and consumed medical
marijuana is necessary to combat the interstate drug trade. Justice O’Connor, a well known
state’s rights proponent, argued in another dissent,
that the majority’s decision infringed on state’s rights. O’Connor believed the decision
gave Congress the power to improperly regulate
any in-state activity it deems essential to the
regulation of interstate commerce. Gonzales versus Raich protected
the federal government’s ability to seize and destroy
marijuana in all 50 states, including in those states that
have legalized marijuana use under state law. The case also represents an expansion of Congress’s Commerce Clause authority to regulate in-state activities. But none of that mattered to Angel Raich. Despite the ruling, she
announced that she’d continue to use medical marijuana
to alleviate her suffering, no matter what the Supreme Court has to say about federalism.

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