The United States v. Morrison case in 2000 was a landmark decision by the Supreme Court of the United States that ruled parts of the Violence Against Women Act (VAWA) as unconstitutional. The court held that Congress lacked authority to enact a statute under both Commerce Clause and Fourteenth Amendment, which provided a civil remedy for victims of gender-motivated violence. The case involved Christy Brzonkala who sued Antonio Morrison and James Crawford, fellow students at Virginia Tech, alleging rape. She sought recourse through VAWA after her complaint was dismissed by university authorities and local law enforcement failed to press charges due to lack of evidence. However, on appeal from Fourth Circuit's ruling favoring defendants' motion to dismiss citing VAWA as exceeding congressional powers under Commerce Clause and Section Five of Fourteenth Amendment; SCOTUS affirmed it with 5-4 majority vote stating such private criminal conduct doesn't sufficiently affect interstate commerce nor does it fall within Congress's power over state conduct.

The United States v. Morrison case was actually decided in 2000, not 1900. In the dissenting opinion for this case, Justice Souter argued that Congress had sufficient evidence to conclude that gender-motivated violence substantially affects interstate commerce and thus falls within its power to regulate under the Commerce Clause of the Constitution. He contended that such violence deters potential victims from traveling interstate, engaging in employment in certain sectors of the economy, and transacting with businesses. Furthermore, he noted that crimes of violence committed against women often result in medical costs which are spread throughout the population via increased insurance premiums and government expenditures on healthcare. Therefore, he believed it was a mistake for the majority to strike down part of Violence Against Women Act as unconstitutional because they failed to defer sufficiently to Congressional findings about its impact on interstate commerce.