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Printz v. United States

521 U.S. 898 (1997)

tl;dr: Anti-commandeering principle extends to preventing federal government from coercing state officials to execute federal programs.

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The case of "Printz, Sheriff/Coroner, Ravalli County, Montana v. United States" questioned whether certain provisions of the Brady Handgun Violence Prevention Act, which require state and local law enforcement officers to conduct background checks on prospective handgun purchasers, violate the Constitution. The Gun Control Act of 1968 establishes federal regulations on firearms distribution, including prohibiting firearms dealers from transferring handguns to certain individuals and forbidding possession of firearms by certain individuals. The Brady Act, which amended the Gun Control Act of 1968, requires the Attorney General to establish a national instant background-check system and includes interim provisions until that system is in place. The lower court's decision is not specified. The Supreme Court must determine whether requiring state officers to participate in federal programs is constitutional by considering the historical context and legislative history.

Early congressional statutes required state courts to record citizenship applications and transmit naturalization records to the Secretary of State, but it may have only applied in states that authorized their courts to conduct naturalization proceedings. The Constitution established only a Supreme Court and made the creation of lower federal courts optional, but the Supremacy Clause announced that federal laws shall be the supreme law of the land and judges in every state shall be bound by them. Early Congresses did not assume that the Federal Government could command the States' executive power without constitutional authorization. The Constitution allows Congress to use State officers and regulations to collect federal taxes and execute federal laws, but these responsibilities cannot be imposed without the consent of the States.

The Supreme Court ruled that the Brady Act's background-check provision, which requires state officers to perform specific tasks specified by Congress, is unconstitutional as it violates state sovereignty and the Constitution's division of power among sovereigns and branches of government. The Court invalidated the provisions of the Brady Act as inconsistent with the Tenth Amendment. The Court did not address the validity of other reporting requirements imposed by Congress on state and local authorities under the Commerce Clause. Justice O'Connor suggests that states and law enforcement officers may voluntarily participate in the federal program, while Justice Thomas emphasizes the limited powers of the Federal Government under the Constitution. Justice Stevens dissents, arguing that the Federal Government's authority under the Commerce Clause does not extend to regulating wholly intrastate, point-of-sale transactions.

The case involves whether Congress can require local law enforcement officers to perform certain duties temporarily while a federal gun control program is being developed. Justice Stevens and three other Justices argue that Congress can impose obligations on state and local officials and citizens, and that federal law is binding on all citizens and courts, including those in the states. The Court's attempts to discount historical evidence supporting the requirement of state officials to implement federal law are not convincing. The Unfunded Mandates Reform Act of 1995 aims to avoid imposing federal mandates on state governments without sufficient funding. Congress may require states to implement its programs as a condition of federal spending or as part of a program that affects states and private parties alike. The requirement for CLEOs to perform background checks under the Brady Act does not involve substantial policymaking discretion. Justice Breyer disagrees with the majority opinion and cites examples of other countries that maintain local control by allowing constituent states to implement laws enacted by the central government.

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IRACIssue, Rule, Analysis, Conclusion

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Facts & Holding

Facts:Congress enacted Brady Handgun violence Prevention Act, which required state...

Holding:Enactments of first early Congresses contained no evidence of an...

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Printz v. United States

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