Printz v. United States

1997-06-27
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Headline: Court strikes down federal rule forcing local police to run handgun background checks, holding Brady Act interim duties unconstitutional and freeing state law enforcement from mandatory federal enforcement.

Holding: The Court held that Congress cannot compel state or local chief law enforcement officers to perform the Brady Act’s interim handgun background checks, making those mandatory duties unconstitutional as applied to the officers who sued.

Real World Impact:
  • Blocks federal requirement forcing local police to perform interim handgun background checks.
  • Leaves unresolved whether dealers must still submit forms or wait five business days.
  • Allows States to volunteer or contract with federal government to continue checks.
Topics: gun buyer checks, state vs federal power, law enforcement duties, Brady Act interim rules

Summary

Background

Two county sheriffs who serve as the chief law enforcement officers of counties in Montana and Arizona sued, objecting to interim provisions of the Brady Handgun Violence Prevention Act. Under those provisions, gun dealers had to give a completed Brady form to the local chief law enforcement officer and wait five business days unless the officer said the sale appeared lawful. The sheriffs argued the law unconstitutionally compelled them to administer a federal program.

Reasoning

The Court asked whether Congress can force state or local executive officers to carry out federal regulatory tasks. It examined early practice, the Constitution’s structure, and prior decisions. The majority concluded that forcing state officers to implement federal law violates the federal system of separate state sovereignty. Relying on history and the Court’s precedents, the Justices held the central duty to “make a reasonable effort” to run five-day background checks was unconstitutional as applied to the officers who sued.

Real world impact

As a result, the mandatory interim duty that made CLEOs (chief law enforcement officers) perform background checks is invalid for these officers, and related receipt-or-destroy record duties are inoperative for them. The Court declined to decide whether gun dealers must still forward forms or wait five days where no CLEO accepts the duty; no dealers or purchasers were plaintiffs here. States and local officials remain free to volunteer to run checks, and Congress may pursue other methods such as contracts or funding.

Dissents or concurrances

A dissent argued Congress could require temporary assistance under its Commerce and Necessary and Proper powers and emphasized public-safety goals and historical practice supporting federal enlistment of local officials. Justice O’Connor concurred that voluntary or contractual participation remains available.

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