The United States v. Antonio J. Morrison, et al., 1999 case revolved around the constitutionality of a provision in the Violence Against Women Act (VAWA) that allowed victims of gender-motivated violence to sue their attackers in federal court. Christy Brzonkala filed a lawsuit against Antonio Morrison and James Crawford under this act, alleging they had raped her while all three were students at Virginia Tech University. The defendants argued that Congress lacked authority to enact VAWA under either the Commerce Clause or Fourteenth Amendment's Equal Protection Clause. In May 2000, the Supreme Court ruled by a 5-4 majority that Congress did not have authority to pass such legislation based on these constitutional provisions. They held that non-economic violent criminal conduct was not part of interstate commerce and thus outside congressional jurisdiction under the Commerce Clause; furthermore, they found no state action involved for invoking Fourteenth Amendment protections as both accused were private individuals rather than state actors.

In the dissenting opinion for United States v. Antonio J. Morrison, et al., Justice Souter, joined by Justices Stevens, Ginsburg and Breyer disagreed with the majority's view that Congress lacked authority under the Commerce Clause to enact a provision of Violence Against Women Act (VAWA). The dissent argued that gender-motivated violence substantially affects interstate commerce and therefore falls within Congress' power to regulate. They contended that such violent acts not only cause substantial harm but also deter potential victims from traveling or engaging in economic activity out of fear. Furthermore, they pointed out historical evidence showing how states have failed to provide adequate remedies for victims of gender-based violence which justified federal intervention through VAWA. The dissenters believed this was an issue requiring national attention and solution rather than being left solely at state level.