Gonzales v. Raich Case Brief

Facts of the case

In 1996 California voters passed the Compassionate Use Act, legalizing marijuana for medical use. California’s law conflicted with the federal Controlled Substances Act (CSA), which banned possession of marijuana. After the Drug Enforcement Administration (DEA) seized doctor-prescribed marijuana from a patient’s home, a group of medical marijuana users sued the DEA and U.S. Attorney General John Ashcroft in federal district court.The medical marijuana users argued the Controlled Substances Act – which Congress passed using its constitutional power to regulate interstate commerce – exceeded Congress’ commerce clause power. The district court ruled against the group. The Ninth Circuit Court of Appeals reversed and ruled the CSA unconstitutional as it applied to intrastate (within a state) medical marijuana use. Relying on two U.S. Supreme Court decisions that narrowed Congress’ commerce clause power – U.S. v. Lopez (1995) and U.S. v. Morrison (2000) – the Ninth Circuit ruled using medical marijuana did not substantially affectinterstate commerce and therefore could not be regulated by Congress.

CONCLUSION

The Court held that the regulation of marijuana under the CSA was squarely within Congress’ commerce power because production of marijuana meant for home consumption had a substantial effect on supply and demand in the national market. Given the enforcement difficulties in distinguishing between marijuana cultivated locally and marijuana grown elsewhere, and concerns about diversion into illicit channels, the Court had no difficulty concluding that Congress had a rational basis for believing that failure to regulate the intrastate manufacture and possession of marijuana would leave a gaping hole in the CSA. Congress was acting well within its authority of the Commerce Clause, U.S. Const., art. I, § 8.

  • Advocates: Paul D. Clement argued the cause for Petitioners Randy E. Barnett argued the cause for Respondents
  • Petitioner: Alberto R. Gonzales, Attorney General, et al.
  • Respondent: Angel McClary Raich, et al.
  • DECIDED BY:Rehnquist Court
  • Location: –
Citation: 545 US 1 (2005)
Granted: Jun 28, 2004
Argued: Nov 29, 2004
Decided: Jun 6, 2005
Gonzales v. Raich Case Brief