Summary of Printz v. U.S.
S. Ct. 1997
Facts: Congress enacted Brady Act requiring Atty Gen to establish a national instant background check system. Under which a purchaser of a handgun cannot be of a category to purchase a handgun, and the Chief Law Enforcement Officer of the resident state will receive the documents certified. A dealer may sell a gun immediately if the purchaser possesses a state handgun permit or if state law provides for an instant background check. If neither then the CLEO are required to perform background checks. County Sheriff in Montana and one in AZ challenge the constitutionality.
Issue: Whether certain provisions of the Brady Bill, commanding State law enforcement to conduct background checks on prospective handgun purchasers, violates the Constitution? Yes
Holding: (1) obligation to conduct background checks on prospective handgun purchasers imposed unconstitutional obligation on state officers to execute federal laws; (2) sheriffs were not in position to challenge Act's requirements that CLEOs destroy handgun-applicant statements and give would-be purchasers written statements of reasons for determining their ineligibility to receive handguns; and (3) there were no plaintiffs before Court who could challenge provisions requiring firearms dealers to forward to CLEO notice of contents of handgun-applicant statement, and to wait five business days before consummating sale.
Procedure: County sheriff sought to enjoin enforcement of provisions of Brady Act imposing requirements on chief law enforcement officers (CLEO). The U S D Ct Mont. held background check requirement to be unconstitutional. Another county sheriff brought separate action to declare Brady Act unconstitutional. The US D Ct for AZ found that background search requirement was unconstitutional. Parties appealed, and cases were consolidated. The Court of Appeals reversed. Certiorari was granted. S Ct Reversed.
Rule: A law carrying into execution the Commerce Clause violates the principle of State sovereignty, it is not a law proper, and is thus not enforceable under Necessary and Proper Clause. U.S.C.A. Const. Art. 1, § 8, cls. 3, 18.
Ct. Rationale: Constitutionally established system of dual sovereignty under which states surrendered many of their powers to federal government but retained residuary and inviolable sovereignty Constitution contemplates that State's governments will represent and remain accountable to its own citizens. Even where Congress has authority under Constitution to pass laws requiring or prohibiting certain acts, Necessary and Proper Clause does not grant Congress power directly to compel states to require or prohibit those acts. The Act violates the 10th.
PL A: Federal government may not compel States to implement, by legislation or executive action, federal regulatory programs.
Def A: Earlier Congresses enacted statutes that required the participation of State Officials in the implementation of Federal Laws. CONSTITUTIONAL MEANING is derived from.