Along with United States v. Lopez (1995), it was part of a series of Rehnquist Court cases that limited Congress's powers under the Commerce Clause.
In his dissenting opinion, Associate Justice David Souter argued that the majority revived an old and discredited interpretation of the Commerce Clause.
Chief Justice Rehnquist, writing for the majority, held that Congress lacked authority, under either the Commerce Clause or the Fourteenth Amendment, to enact that provision.
With regard to the Commerce Clause, the majority said that the result was controlled by United States v. Lopez (1995), which had held that the Gun-Free School Zones Act of 1990 was unconstitutional.
Once again, relying on Lopez, the majority replied that the aggregation principle of Wickard did not apply because economic effects of crimes against women were indirect and so they could not be addressed through the Commerce Clause.
Justice Thomas's concurring opinion also expressed the concern that "Congress [was] appropriating State police powers under the guise of regulating commerce."
The majority, quoting from NLRB v. Jones & Laughlin Steel Corp. (1937), stated that the scope of the interstate commerce power must be considered in the light of our dual system of government and may not be extended so as to embrace effects upon interstate commerce so indirect and remote that to embrace them, in view of our complex society, would effectually obliterate the distinction between what is national and what is local and create a completely centralized government.The Court also held that Congress lacked the power to enact VAWA under the Fourteenth Amendment.
The U.S. government argued that VAWA appropriately enforced the Equal Protection Clause's ban on governmental gender discrimination.
Specially, the government argued that pervasive gender stereotypes and assumptions permeated state justice systems and that such forms of state bias led to "insufficient investigation and prosecution of gender-motivated crime, inappropriate focus on the behavior and credibility of the victims of that crime, and unacceptably lenient punishments for those who are actually convicted of gender-motivated violence."
The Court agreed with the government that there was a "voluminous congressional record" supporting the "assertion that there is pervasive bias in various state justice systems against victims of gender-motivated violence."
According to the Court, however, the Civil Rights Cases held that the Fourteenth Amendment did not allow Congress to target private parties to remedy the unequal enforcement of state laws.
To the majority, that quote indicated that the law deemed unconstitutional in the Civil Rights Cases was meant to combat the same kind of disparate treatment against which VAWA was aimed.
The majority continued that even if the government's distinction between Morrison and the Civil Rights Cases was valid, the VAWA remained unconstitutionally aimed not at state actors but at private criminal conduct.
The Court also noted that unlike the VAWA, the legislation in Morgan "was directed only to the State where the evil found by Congress existed."
"[10] Morrison, like Boerne, Kimel, and Garrett, was one of a series of Rehnquist Court decisions from 1999 through 2001 holding that Congress's enumerated powers do not permit various federal civil rights laws.