Gonzales v. Raich

Angel Raich and Diane Monson were California residents who used marijuana for serious medical conditions under California's Compassionate Use Act. Monson grew her own marijuana at home, and Raich obtained hers from local caregivers at no cost. Federal DEA agents seized and destroyed Monson's marijuana plants under the Controlled Substances Act. Raich and Monson sought injunctive relief, arguing the CSA exceeded Congress's commerce power as applied to locally grown, noncommercial medical marijuana.

Justice Stevens's majority opinion distinguished Lopez and Morrison by characterizing marijuana cultivation as quintessentially economic activity -- the production of a commodity meant for home consumption that has a direct substitute in interstate markets, paralleling the wheat in Wickard. The Court held that Congress could rationally conclude that leaving home-consumed marijuana outside federal regulation would create an enforcement gap that would undermine the CSA's comprehensive regulatory scheme. The Necessary and Proper Clause provided additional authority to reach purely local activities as part of a broader regulatory framework.

Raich clarified that the economic/noneconomic distinction from Lopez and Morrison turns not on whether the specific regulated activity is commercial but on whether the broader class of activity is economic in character. The decision confirmed that Congress retains broad power to regulate as part of comprehensive regulatory schemes, even when individual instances of the regulated activity are purely local.