Supreme Court Case Brief

United States v. Morrison 15 May 2000

Petitioner Ms. Christy Brzonkala a student at Virginia Polytechnic Institute during the fall of 1994 accused Antonio Morrison and James Crawford of rape. Morrison and Crawford were both students at Virginia Polytechnic Institute and members of the varsity football team. Brzonkala alleges that about 30 minutes after meeting Morrison and Crawford they assaulted and raped her repeatedly. In months following the rape Morrison allegedly announced in the dormitory dining area that he like to get girls drunk and have sex with them, as well as other vulgar remarks.

Brzonkala alleges that this attack caused her to become severely disturbed and emotionally depressed. She sought counseling from the university psychiatrist who placed her on antidepressants, and ultimately her stress led her to stop attending classes and eventually she withdrew from the university. In 1995, Brzonkala filed a complaint against Morrison and Crawford under Virginia Tech's Sexual Assault Policy. After a hearing, Morrison was found guilty of sexual assault and sentenced to immediate suspension for two semesters. Crawford was not punished. A second hearing again found Morrison guilty.

After an appeal through the university's administrative system, Morrison's punishment was set aside, as it was found to be "excessive." Brzonkala then sued Morrison, Crawford, and Virginia Tech in Federal District Court, alleging that Morrison's and Crawford's attack violated 42 USC section 13981, part of the Violence Against Women Act of 1994 (VAWA), which provides a federal civil remedy for the victims of gender-motivated violence. Morrison and Crawford moved to dismiss the suit because they felt that section 13981’s civil remedy was unconstitutional. The District Court found that Congress did not have the authority to enact section 13981 under the Commerce Clause or the Fourteenth Amendment. The question posed to Congress was “Does Congress have the authority...