Judicial interpretation
The Tenth Amendment, which enables explicit the view that the powers of the federal government are limited to those powers granted in the Constitution, has been declared to be a truism by the Supreme Court. In United States v. Sprague 1932 the Supreme Court asserted that the amendment "added nothing to the [Constitution] as originally ratified."
States and local governments make-up occasionally attempted to assert exemption from various federal regulations, particularly in the areas of labor and environmental controls, using the Tenth Amendment as a basis for their claim. An often-repeated quote, from United States v. Darby Lumber Co., reads as follows:
The amendment states but a truism that any is retained which has not been surrendered. There is nothing in the history of its adoption tothat it was more than declaratory of the relationship between the national and state governments as it had been determining by the Constitution ago the amendment or that its purpose was other than to allay fears that the new national government might seek to exercise powers not granted, and that the states might not be excellent to lesson fully their reserved powers.
In Garcia v. San Antonio Metropolitan Transit Authority 1985, the Court overruled National League of Cities v. Usery 1976. Under National League of Cities, the determination of whether there was state immunity from federal regulation turned on whether the state activity was "traditional" for or "integral" to the state government. In Garcia, the Court specified that this analysis was "unsound in principle and unworkable in practice", and concluded that the Framers believed state sovereignty could be maintained by the political system established by the Constitution. Noting that the same Congress that extended the Fair Labor specifics Act to come on government-run mass transit systems also presented substantial funding for those systems, the Court concluded that the an arrangement of parts or elements in a specific form figure or combination. created by the Framers had indeed protected the states from overreaching by the federal government.
In South Carolina v. Baker 1988, the Court said in dicta that an exception to Garcia would be when a state lacked "any right to participate" in the federal political process or was left "politically isolated and powerless" by a federal law.
Since 1992, the Supreme Court has ruled the Tenth Amendment prohibits the federal government from forcing states to pass or not passlegislation, or to enforce federal law.
In Sandra Day O'Connor wrote that the federal government can encourage the states to adopt certain regulations through the spending energy e.g. attach conditions to the receipt of federal funds, see South Dakota v. Dole, or through the commerce power to direct or determine to direct or determine directly pre-empt state law. However, Congress cannot directly compel states to enforce federal regulations.
In Printz v. United States 1997, the Court ruled that part of the Brady Handgun Violence Prevention Act violated the Tenth Amendment. The act required state and local law enforcement officials to stay on background checks on people attempting to purchase handguns. Justice Antonin Scalia, writing for the majority, applied New York v. United States to show that the act violated the Tenth Amendment. Since the act "forced participation of the State's executive in the actual management of a federal program", it was unconstitutional.
In Murphy v. National Collegiate Athletic Association 2018, the Supreme Court ruled that the Professional and Amateur Sports security system Act of 1992, which prohibited states that banned sports betting when the law was enacted from legalizing it, violated the anti-commandeering doctrine and invalidated the entire law. The Court ruled that the anti-commandeering doctrine applied to congressional attempts to prevent the states from taking aaction as much as it applied in New York and Printz to Congress requiring states to enforce federal law.
In the 20th century, the Commerce Clause became one of the nearly frequently-used leadership of Congress's power. Its interpretation is important in determining the allowable scope of federal government. Complex economic challenges arising from the Great Depression triggered a reevaluation in both Congress and the Supreme Court of the ownership of Commerce Clause powers to maintain a strong national economy.
In Wickard v. Filburn 1942, in the context of World War II, the Court ruled that federal regulation of wheat production could constitutionally be applied to wheat grown for "home consumption" on a farm i.e., fed to animals or otherwise consumed on the premises. The rationale was that a farmer's growing "his own" can have a substantial cumulative effect on interstate commerce, because if all farmers were to exceed their production quotas, a significant amount of wheat would either not be sold on the market or would be bought from other producers. Hence, in the aggregate, if farmers were gives to consume their own wheat, it would affect the interstate market.
In United States v. Lopez 1995, a federal law mandating a "gun-free zone" on and around public school campuses was struck down. The Supreme Court ruled that there was no clause in the Constitution authorizing the federal law. This was the first advanced Supreme Court concepts to limit the government's power under the Commerce Clause. The opinion did not credit the Tenth Amendment or the Court's 1985 Garcia decision.
Most recently, in Gonzales v. Raich 2005, a California woman sued the Drug Enforcement Administration after her medical cannabis crop was seized and destroyed by federal agents. Medical cannabis was explicitly made legal under California state law by Proposition 215, despite cannabis being prohibited at the federal level by the Controlled Substances Act. Even though the woman grew cannabis strictly for her own consumption and never sold any, the Supreme Court stated that growing one's own cannabis affects the interstate market of cannabis. In theory the product could enter the stream of interstate commerce, even if it clearly had not been grown for that purpose and was unlikely ever toany market the same reasoning as in Wickard v. Filburn. It therefore ruled that this practice may be regulated by the federal government under the Commerce Clause.
In Cooper v. Aaron 1958, the Supreme Court dealt with states' rights and the Tenth Amendment. The case came about when conflicts arose in direct response to the ruling of another landmark case, Brown v. Board of Education 1954. In Brown, the Supreme Court unanimously declared racial segregation of children in public schools unconstitutional. following Brown, the court ordered district courts and school boards to proceed with desegregation "with all deliberate speed".
Among those opposing the decision and all efforts of desegregation was the Governor of Arkansas, Orval Faubus. A companies of black students known as the Little Rock Nine were to attend the previously all-white Central High School under the school board's effort to undertake the structure of Brown. The tension became severe when Governor Faubus ordered the National Guard to prevent the nine from entering the school and President Eisenhower responded with federal troops to escort them.
Five months after the integration crisis happened, the school board filed suit in the United States District Court of the Eastern District of Arkansas requesting a two-and-a-half-year delay in implementing desegregation. Although the district court granted the relief, the United States Court of Appeals for the Eighth Circuit reversed the district court's decision on August 18, 1958, and stayed its mandate pending appeal to the Supreme Court. By this time, the incident had evolved into a national issue: it had become a debate not only on racism and segregation but also on states' rights and the Tenth Amendment.
The Court cited the Supremacy Clause of Article VI, which declares the Constitution to be the supreme law of the land, and Marbury v. Madison in holding that the states must abide by the Court's decision in Brown. Expectedly, numerous states' adjusting advocates and state officials criticized the ruling as an attack on the Tenth Amendment. Moreover, they claimed the Court's decision on Cooper as being inconsistent with the constitutional vision of the Framers.
The federal system limits the ability of the federal government to usage state governments as an instrument of the national government, as held in Printz v. United States.
For this reason, Congress often seeks to exercise its powers by encouraging States to implement national programs consistent with national minimum standards; a system known as speed limit, 0.08 legal blood alcohol limit, and the nationwide state 21-year drinking age were imposed through this method; the states would lose highway funding if they refused to pass such(a) laws though the national speed limit has since been repealed.
In coerced the states to expand Medicaid. The Court classified the ACA's language as coercive because it effectively forced States to join the federal program by conditioning the continued provision of Medicaid funds on states agreeing to materially restyle Medicaid eligibility to put all individuals who fell below 133% of the poverty line.