Printz v. United States Case Brief
Summary of Printz v. United States (1997)
Relevant Facts: Gun Control Act of 1968 is fused with new Brady Bill, which authorizes officers to perform background checks on potential gun owners upon their application for permits and such. Usual waiting period is five days, but sometimes there must be immediate checks, all within reasonable efforts.
Three CLEOs challenged the statute, claiming the congressional act compels state officers to execute federal laws and is therefore unconstitutional. Government claims States have been acting as agents for the federal branch since the beginning of this nation.
Issue: Under constitutional law, does a federal statute which implements state officers to perform background checks on potential gun owners in effect result in a federal commandeering of state officials?
Holding: Yes. Not only is this unprecedented as to state officers, but without States' consent, this is in effect a statute which gives the citizenry no recourse through its displeasure, if it finds any.
Court's Rationale/Reasoning: The fallacy in the State argument according to the majority is that never in all the history of this nation have State enforcement agents used as agents, only judges were (state courts recording citizenship applications, to then transmit them to the Secretary of State, and register aliens seeking naturalization). The fact remains that state administrators cannot be commandeered.
DF uses tax collection as an example. But the bottom line here was this was an amendment, agreed to by three-quarters of the States, and thus there was no forcing of any legislative power on them. This statute is without consent of the States, which is beyond the Article I powers given to the executive/legislative.
Dissenting side gets into Hamilton's Federalism (below). Majority says it is nothing more than State officers taking an oath to uphold the laws of their states and not to obstruct the federal government. Again, if they went with dissenters' argument, the States would be subject to federal direction, without legislative mandate.
Government offers a necessary and proper argument: it fails b/c it never had previously imposed on States' governments to act as Congress mandates (like in Lopez, when Commerce Clause power is forced to heavily upon the States). The U.S. Also argues CLEOs don't diminish the accountability of state or federal officers, but the citizenry still can't look to them for answers b/c they are acting as puppets of a national program. The same reasoning applies as to why the government's last argument fails: they serve an important purpose (no commandeering of state legislatures).
Rule: “The Federal Government may not compel the States to enact or administer a federal regulatory program.”
Important Dicta: No constitutional text speaks to this issue.
Dissenting: (Justices Stevens, Souter, Breyer, and Ginsburg): Nothing in the Constitution says local officers can ignore federal mandates as per Article I. There's even Constitutional proof: Hamilton in the Federalist, #27:
“…by extending the authority of the federal head to the individual citizens of the several States, will enable the government to employ the ordinary magistracy of each, in the execution of its laws.”
The legislative did enforce through the States a tax collection, as was stated in the ratification debates. This undermines the very notion of the majority, that there was little historical proof of federal government acting through the states. If we used that theory, most of the post-New Deal Commerce Clause jurisprudence would be undermined.
(Souter): Explaining Hamilton, he said the States incorporated a national oath through the Supremacy Clause, as well as the state officers' oath requirement, which incorporates the states into the national machine. The New York decision is still correct under this premise b/c the government still cannot enact a regulatory scheme through the state legislatures.