United States v. Comstock

Brief Fact Summary.

Congress enacted a statute that allows federal district courts to order the civil commitment of mentally ill, sexually dangerous federal prisoners beyond the dates they would otherwise be released. It is alleged that the statute violates the Article I of the Constitution.

Synopsis of Rule of Law.

Congress possesses broad authority to enact laws in the course of “carrying into execution” its enumerated powers.

Facts.

The federal government enacted a statute that allows federal district courts  to order the civil commitment of mentally ill, sexually dangerous federal prisoners beyond the dates they would otherwise be released. The Court at issue tries to find whether Congress has the authority under the Necessary and Proper Clause to enact such a statute or whether doing so falls beyond the reach of a government of enumerated powers.

Issue.

Does the federal government have the authority under the Article I of the Constitution to enact a statute that allows federal district courts to order the civil commitment of mentally ill, sexually dangerous federal prisoners beyond the dates they would otherwise be released?

Held.

Yes, Congress has the power under the Article I of the Constitution to enact the statute at issue because of its broad power granted by the Constitution and the statute properly accounts for state interests. Thus, the statute shall be held valid.

Dissent.

Justice Thomas

Justice Thomas: Congress may enact a statute only if it is necessary and proper for carrying into execution federal powers enumerated in the Constitution. The government, however, has failed to identify any enumerated power as a constitutional justification for the enactment of the statute. By admitting the statute, the majority risks transforming the Necessary and Proper Clause into a basis for a federal police power, which is not permitted under the Constitution.

Concurrence.

Justice Kennedy and Alito

Justice Kennedy: The Court should first consider whether essential attributes of state power are compromised by the assertion of federal power under the Necessary and Proper Clause. If that is the case, that suggests that the federal power may not be valid within the Constitution.

Justice Alito: It is crucial that Congress should protect the public from dangers posed by federal prisoners. Congress has under the Necessary and Proper Clause to provide for the civil commitment of dangerous prisoners who would otherwise escape civil commitment due to federal imprisonment.

Discussion.

Congress enjoys a broad authority under the Necessary and Proper Clause to enact federal law that is “convenient, or useful” or conducive to the authority’s “beneficial exercise.” The statute constitutes a means that is rationally related to the implementation of a constitutionally enumerated power. Moreover, the federal government is the custodian of its prisoners and has the constitutional power to act to protect the communities from the danger federal prisoners may pose. The statute seeks to facilitate the federal protection of the people. Various considerations make the statute necessary and proper means of exercising the federal authority that allows Congress to create federal criminal laws, to punish wrongdoers, and to maintain the security of our community.