Gonzales v. Raich

545 U. S. 1 (2005)

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Nature of the Case

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Facts

Ps are California residents who suffer from serious medical conditions and have sought to avail themselves of medical marijuana pursuant to the terms of California's Compassionate Use Act. Their licensed, board-certified family practitioners have concluded that marijuana is the only drug available that provides effective treatment. P's physician believes that forgoing cannabis treatments would certainly cause Raich (P) excruciating pain and could very well prove fatal. Monson (P) cultivates her own marijuana. Raich (P) relies on two caregivers, litigating as 'John Does,' to provide her with locally grown marijuana at no charge. County deputy sheriffs and agents from the federal Drug Enforcement Administration (DEA) came to Monson's (P) home. After a thorough investigation, the county officials concluded that her use of marijuana was entirely lawful as a matter of California law. Nevertheless, after a 3-hour standoff, the federal agents seized and destroyed all six of her cannabis plants. Ps brought this action against the Attorney General of the United States and the head of the DEA seeking injunctive and declaratory relief prohibiting the enforcement of the federal Controlled Substances Act to the extent it prevents them from possessing, obtaining, or manufacturing cannabis for their personal medical use. Ps claimed that enforcing the CSA against them would violate the Commerce Clause, the Due Process Clause of the Fifth Amendment, the Ninth and Tenth Amendments of the Constitution, and the doctrine of medical necessity. The District Court denied Ps' motion for a preliminary injunction. It concluded that Ps could not demonstrate a likelihood of success on the merits of their legal claims. The Ninth Circuit reversed and ordered the District Court to enter a preliminary injunction. It held that the CSA is an unconstitutional exercise of Congress' Commerce Clause authority. It focused on the intrastate, noncommercial cultivation and possession of cannabis for personal medical purposes as recommended by a patient's physician pursuant to valid California state law. This separate class of purely local activities was beyond the reach of federal power. The dissenting judge thought it 'simply impossible to distinguish the relevant conduct surrounding the cultivation and use of the marijuana crop at issue in this case from the cultivation and use of the wheat crop that affected interstate commerce. The Supreme Court granted certiorari.