Raich v. Gonzales
"Raich v. Gonzales" is a significant case concerning the clash between state laws permitting the medical use of marijuana and federal law prohibiting it. Following California's 1996 Compassionate Use Act, which allowed the cultivation and use of marijuana for medical purposes, Angel Raich and others took legal action against the federal government after the Drug Enforcement Administration (DEA) destroyed their medical marijuana plants. The case reached the Ninth Circuit Court of Appeals, which ruled in favor of Raich, asserting that federal statutes were unconstitutional when applied to intrastate, noncommercial medical use. However, the U.S. Supreme Court reversed this decision in a 6-3 ruling. The majority opinion, authored by Justice John Paul Stevens, emphasized Congress's power to regulate local activities that substantially affect interstate commerce, arguing that the federal government’s authority extended to all forms of marijuana cultivation, regardless of state laws. This decision underscored the complexities of federalism, particularly in the context of evolving perceptions of marijuana use and its legal status across different states.
Raich v. Gonzales
Date: June 6, 2005
Citation: 545 U.S. ‗‗‗‗
Issue(s): Commerce clause; controlled substances
Significance: The Supreme Court recognized the federal government’s authority to enforce federal laws outlawing marijuana in all circumstances, even in those states that have legalized the substance for some medical purposes.
In 1996, California legalized the use of marijuana for medicinal purposes in the so-called Compassionate Use Act, which was similar to the statutes in ten other states. All such statutes conflicted with the federal Controlled Substance Act (1970), which criminalized the possession of marijuana for any purpose. After agents of the Drug Enforcement Administration (DEA) destroyed the marijuana and cannabis plants grown by Angel Raich in her garden, Raich joined with other concerned parties to sue the attorney general and the DEA in federal district court.
The Ninth Circuit Court of Appeals ruled that the DEA’s application of the federal statute was unconstitutional insofar as it applied to the intrastate, noncommercial possession and cultivation of a substance for medical use as recommended by a physician. The court pointed to the United States v. Lopez (1995), in which the Supreme Court had held that federal power did not extend to the regulation of purely local activities.
The Supreme Court, however, upheld the federal government’s position by a 6-3 vote. In the opinion for the majority, Justice John Paul Stevens wrote that the commerce claused empowered Congress to prohibit the local cultivation and use of controlled substances, despite state laws to the contrary. He argued that the commerce clause authorized Congress to regulate any “class of activities” that substantial affects interstate commerce. The case was different from Lopez, which related to a noneconomic activity having no significant impact on interstate commerce. Because of the difficulty in distinguishing between marijuana cultivated locally and marijuana grown elsewhere, Stevens affirmed that Congress acted rationally in placing this class of activities within the larger regulatory scheme. He also observed that marijuana has a high potential for abuse and no generally recognized medical use.