Facts of the Case
Carol Anne Bond worked for the chemical manufacturer Rohm and Haas. When she learned that her friend Myrlinda Haynes was pregnant and that Bond's husband was the father, she used her connections with the chemical company to obtain the means for revenge. She stole and purchased highly toxic chemicals that she applied to Haynes' doorknobs, car door handles, and mailbox. Haynes suffered a minor burn, and after contacting a federal investigator, Bond was identified as the perpetrator. She was charged with several violations of the Chemical Weapons Convention Implementation Act of 1998 (Act).
In the district court, Bond moved to dismiss the case and argued that Congress did not have the authority to enforce the Act because it subverted states' rights in violation of the Tenth Amendment. The district court denied the motion, and Bond conditionally pled guilty with the understanding that she could continue to appeal the decision regarding the validity of the Act. She was sentenced to six years in prison. Bond renewed her challenge to the Act in the U.S. Court of Appeals for the Third Circuit, which held that Bond did not have standing to appeal. The U.S. Supreme Court reversed the decision and held that the case must be considered on its merits. The case was remanded back to the U.S. Court of Appeals for the 3d Circuit. The Court of Appeals held that the Act was within Congress' power to enact and enforce.
Does Congress have the authority to enact legislation that enforces a treaty but goes beyond the scope of the treaty and intrudes on traditional state prerogatives?
Can the Chemical Weapons Convention Implementation Act be properly interpreted so that it does not apply to ordinary poisoning cases, which have been traditionally handled by state and local authorities?
No, yes. Chief Justice John G. Roberts, Jr. delivered the opinion for the 6-3 majority. The Court held that federal law typically does not intrude on the ability of states to regulate local matters, and the Chemical Weapons Convention Implementation Act is not an exception to that general rule. While Congress has the authority to create legislation to enforce treaties, it must do so while respecting the traditional division of sovereign responsibility between the federal government and the states. The Court also held that it is incumbent upon the courts to be sure of Congress' intent before ruling based on such a rationale; in this case, because there is no evidence that Congress intended the statute to have expansive powers, it must be read more narrowly. In fact, the language of the statute suggests that the facts of this case do not match the types of situations the statute was enacted to govern.
Justice Antonin Scalia wrote an opinion concurring in the judgment in which he argued that, in determining whether the Chemical Weapons Convention Implementation Act covers Bond's actions, the majority opinion overstepped its bounds and performed Congress' duty. Justice Scalia also wrote that it was clear from the wording of the statute that Bond's actions were covered, and the majority opinion's interpretation of the statute made it so broad as to be unintelligible. However, the statute was unconstitutional because it infringed on the rights of the states. Justice Clarence Thomas and Justice Samuel A. Alito, Jr. joined in the opinion concurring in the judgment. In his separate opinion concurring in the judgment, Justice Thomas wrote that, while Congress has the power to create laws that enforce treaties, that power does not extend to the enforcement of laws that would infringe on states' rights. The historical context of this "Treaty Power" indicates that it was meant to be limited to international affairs and not interfere with the constitutional structure of federal and state power. Justice Scalia and Justice Alito joined in the concurrence in judgment. Justice Alito also wrote a separate opinion concurring in the judgment in which he argued that the statute went beyond Congress' power to enforce treaties and is therefore unconstitutional.
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