United States v. Morrison, decided in 2000, is one controversial successor case. In that case, the Supreme Court, applying the congruent-and-proportional Boerne test, overturned provisions of the Violence Against Women Act (VAWA), which created federal civil jurisdiction over gender-based violence. The Court held that Congress did not have the power to enact a remedy targeting private action rather than state action, and that it could not enact a Section 5 remedy without findings of national, or near-national, harm.
United States v. Morrison, decided in 2000, is one controversial successor case. In that case, the Supreme Court, applying the co?ngruent-and-proportional Boerne test, overturned provisions of the Violence Against Women Act (VAWA), which created federal civil jurisdiction over gender-based violence. The Court held that Congress did not have the power to enact a remedy targeting private action rather than state action, and that it could not enact a Section 5 remedy without findings of national, or near-national, harm.