Printz v.  United States Summary |
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Printz v. United States Summary |

– [Narrator] The United
States Supreme Court is known to save the announcement of its most controversial case for the last day of each term. It’s no wonder that Printz
versus United States was announced just as the
justices were headed out the door to close the 1997 term. The case raises deeply divisive issues involving gun control
and the balance of power between the states and
the federal government. Enacted by Congress in 1993,
the Brady Handgun Violence Prevention Act was a
federal gun control statute that established a nationwide handgun background check system. While gearing up to implement
the nationwide system, interim provisions of the Brady Act temporarily required
state and local officials, rather than federal officials, to conduct the background checks of
prospective firearm purchasers. Under these interim
provisions, firearm sellers were required to report
pending firearm sales to county police chiefs
who were then required to conduct a background
check and validate the sale. County sheriffs Joe
Printz and Richard Mack brought separate lawsuits
arguing that the Brady Act unconstitutionally
compelled state officers to enforce a federal statute. Both district courts agreed
and struck down the provision as unconstitutional. The court of appeals for the ninth circuit consolidated the cases and reversed, holding that the interim
provision was constitutional. The United States Supreme
Court granted cert. The issue before the
court was whether Congress can compel state officials to participate in the implementation
of a federal program. The court held that under the 10th Amendment’s
anti-commandeering principle, Congress may not compel state officials to administer a federal
regulatory program. Justice Scalia, writing
for the five to four court, explained that there was
no historical evidence that Congress ever had the power to compel state executives into federal service. Early congressional enactments showed that the constitution
allowed the imposition of federal standards only on state judges who apply those standards
in deciding cases, but not on officers of the
state’s executive branch. Next, Scalia considered how the Brady Act conflicted with constitutional structure. First, the 10th Amendment sets up a system of dual sovereignty under which the states retain a
significant amount of autonomy. Scalia noted that the act upset
the careful balance of power between the federal
government in the states. Federal power would increase
dramatically, Scalia reasoned, if it could enlist into service the police officers of the 50 states. Additionally, the court
held that the Brady Act violated the constitutional
separation of powers principle because the power to
execute the laws is provided to the president and federal executive branch officials only. Congress can’t delegate
federal executive power to state law enforcement officers as it attempted to do here. Lastly, the court cited New
York versus United States which had determined
that Congress can’t force state legislators to enact laws according to federal instructions. Scalia concluded that because Congress can’t mandate state legislatures to act, it can’t mandate state executive
officers to act either. As a result, the court
held that the Brady Act’s employment of state officers to conduct background searches was unconstitutional. The court reversed the court of appeals. Justice O’Connor filed
a concurring opinion to note that state officials
could still voluntarily comply with the Brady Act,
despite the court’s decision. Justice Thomas wrote a concurring opinion agreeing with the court’s analysis but further arguing that
under the current state of the commerce clause doctrine, congress didn’t have the authority to regulate the in-state
transfer of firearms. Justice Stevens dissented. He argued that Congress had the authority to enact the Brady Act
under the commerce clause. Congress may also impose
enforcement obligations on state officials under the
necessary and proper clause. Stevens reasoned that the
framers envisioned a system in which the federal government may act for the benefit of the nation as a whole, and this sometimes requires the power to make demands on state officials. In another dissenting opinion, Justice Souter examined the
text of a federalist paper, the supremacy clause, and oaths taken by state officers to advance the argument that state officials can
be enlisted into service on behalf of the national government. Finally, Justice Breyer also dissenting, cited examples from foreign nations to demonstrate that successful
systems of government employed local authorities to carry out national regulations. Printz versus United States was
a monumental federalism case memorable for its narrow
interpretation of federal power and its staunch protection of state autonomy from federal incursion.


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