Gonzales v. Raich, 545 U.S. 1 (2005)
Primary Holding
Congress has the authority under the Commerce Clause to prohibit the local cultivation and use of marijuana for medicinal purposes, even when such activities are permitted by state law.
In the case of Gonzales v. Raich, the Supreme Court decided that the federal government can ban the use of marijuana, even in states like California where it's legal for medical purposes. This matters because it means that federal law can override state laws when it comes to certain drugs, which can affect patients who rely on medical marijuana for their health. For consumers, this ruling highlights that while some states may allow medical marijuana, patients can still face legal issues at the federal level. This case is relevant for anyone considering using medical marijuana, as it shows the risks involved due to conflicting state and federal laws.
AI-generated plain-language summary to help you understand this case
Angel Raich, a California resident, grew marijuana for her personal medical use. Another California resident, Diane Monson, grew six marijuana plants that were destroyed in a raid by federal officials from the Drug Enforcement Administration. The plants grown by Raich and Monson were legal in California under Proposition 215, which permitted the medical use of marijuana, but illegal under the federal Controlled Substances Act, which classified them as Schedule I drugs. Raich, Monson, and two caregivers brought a suit to protect their right to grow and use marijuana for medical purposes. Raich's doctor stated that she would be in extreme, life-threatening pain if she did not use the marijuana as allowed under the California Compassionate Use Act. She was allergic to most conventional types of prescription drugs. Monson suffered from pain and muscle spasms around her spine after a car accident, and she used marijuana to alleviate those symptoms. However, the DEA was determined to eradicate the medical marijuana co-ops in California, reflecting an understanding that the Controlled Substances Act pre-empted California laws. Unsympathetic to the government's arguments that the Commerce Clause gave it the authority to regulate in this area, the Ninth Circuit granted a preliminary injunction to prevent interference with Raich and Monson. Several states and organizations on each side of the debate filed amicus curiae briefs with the Supreme Court.
Whether the power vested in Congress by Article I, §8, of the Constitution to regulate commerce includes the authority to prohibit the local cultivation and use of marijuana in compliance with California law.
The judgment is affirmed.
This decision marks a potential return in the Commerce Clause doctrine of the Court to the expansive understanding of Congressional powers under it in the mid-20th century. The Court had found more limitations on that power in recent cases, but it managed to distinguish them here. Despite the failure of this claim as well as subsequent litigation and legislative efforts, Raich and Monson continue to use marijuana for private medical purposes. The federal government has stated that it does not prioritize enforcing the CSA against such users, and it is likely that Raich could defend her use on the grounds of medical necessity, carving out an exception to the law even if it is not unconstitutional.
- Court
- Supreme Court
- Decision Date
- November 29, 2004
- Jurisdiction
- federal
- Case Type
- landmark
- Majority Author
- Stevens
- Damages Awarded
- N/A
- Data Quality
- high
Granholm v. Heald, 544 U.S. 460 (2005)
Consumer WonState laws that allow in-state wineries to sell wine directly to consumers while prohibiting or restricting out-of-state wineries from doing the same violate the Commerce Clause of the Constitution, and such discrimination is not permitted by the Twenty-first Amendment.
Illinois v. Caballes, 543 U.S. 405 (2005)
Consumer LostThe use of a drug-detection dog to sniff a vehicle during a lawful traffic stop does not violate the Fourth Amendment, provided that the stop is not unreasonably prolonged beyond the time necessary to complete the mission of issuing a warning ticket.
Orff v. United States, 545 U.S. 596 (2005)
Consumer LostCongress did not waive the United States' sovereign immunity for suits brought by third-party beneficiaries under the Reclamation Reform Act of 1982, and therefore, individuals who are not parties to a government contract cannot sue the United States for breach of that contract.
San Remo Hotel, L. P. v. City and County of San Francisco, 545 U.S. 323 (2005)
Consumer LostFederal courts cannot create an exception to the full faith and credit statute, 28 U.S.C. §1738, for claims brought under the Takings Clause of the Fifth Amendment, thereby affirming that state court decisions on takings claims must be respected in federal court.