## Facts

- California’s Compassionate Use Act of 1996 allowed limited possession and cultivation of marijuana for medical use with a physician’s recommendation.
- Federal law, through the Controlled Substances Act (CSA), classified marijuana as a Schedule I substance and generally prohibited its manufacture, distribution, and possession.
- Angel Raich and Diane Monson used marijuana for serious medical conditions in compliance with California law.
- Monson cultivated marijuana plants for personal medical use; Raich obtained marijuana without charge from caregivers.
- Federal agents seized and destroyed Monson’s marijuana plants during an enforcement action, despite local officials’ view that she complied with state law.
- Raich and Monson sued federal officials seeking declaratory and injunctive relief to bar CSA enforcement against their intrastate, noncommercial medical marijuana activities.

## Issues

1. Whether Congress, under the Commerce Clause and the Necessary and Proper Clause, may prohibit the local cultivation and possession of marijuana for medical use that is lawful under state law as part of the CSA’s broader regulatory scheme.

## Decision

- The Supreme Court reversed the Ninth Circuit and upheld application of the CSA to respondents’ intrastate, noncommercial medical marijuana.
- The Court held Congress could rationally conclude that exempting local cultivation and use would undercut the CSA’s comprehensive regulation of the interstate drug market.
- The Court treated respondents’ conduct as part of a broader class of activities affecting the national marijuana market, rather than a separate, non-economic category beyond federal reach.
- The Court distinguished prior limits on Commerce Clause power because the CSA is a comprehensive economic regulatory program addressing a commodity with an established interstate market.
- A concurrence reasoned that regulating intrastate cultivation and possession is permissible as a necessary and proper means to effectuate Congress’s regulation of interstate drug trafficking.
- Dissents argued the decision improperly expanded federal power and impaired states’ ability to experiment with medical marijuana policy.

## Legal Principles

- Congress may regulate intrastate activity, even if noncommercial, when it is part of a class of activities that in the aggregate substantially affects interstate commerce.
- When Congress enacts a comprehensive regulatory regime governing an interstate market, it may reach local instances if exempting them would frustrate the scheme.
- Under the Necessary and Proper Clause, Congress may regulate intrastate conduct as an essential component of a valid regulation of interstate economic activity.
- The de minimis character of an individual instance does not bar federal regulation when the statute substantially relates to commerce and targets a broader market.
- State authorization of medical marijuana does not immunize individuals from federal prohibition under the CSA.

## Conclusion

The Court held that Congress may apply the CSA to local cultivation and possession of medical marijuana permitted by state law because regulating such intrastate conduct is a rational and necessary means of protecting the CSA’s comprehensive control of the interstate controlled-substances market.


Gonzales v. Raich, 545 U.S. 1 (2005)