In Comstock v. United States, 560 U.S. 126, 130 S. Ct. 1949 (2010), the majority of the Supreme Court confirmed Justice Scalias view that the Necessary and Proper Clause empowers Congress to enact legislation that is reasonably adapted to effectuating an enumerated power. Specifically, in Comstock, the Supreme Court upheld a federal civil-commitment statute that authorizes the Department of Justice to detain a mentally ill, sexually dangerous federal prisoner beyond the date the prisoner would otherwise be released, 18 U.S.C. 4248. 130 S. Ct. at 1954. The Court concluded that Congress had such power based upon the Necessary and Proper Clauses authorization to implement the Commerce Clause and other enumerated powers. It explained that to determine whether a statute was a constitutional exercise of the Necessary and Proper Clause power we look to see whether the statute constitutes a means that is rationally related to the implementation of a constitutionally enumerated power. Id. at 1956. The civil-commitment statute was constitutional, therefore, as it was reasonably adapted to Congresss power to act as a responsible federal custodian, a power that rests, in turn, upon federal criminal statutes that legitimately seek to implement constitutionally enumerated authority, including the Commerce Clause power. Id. at 1961, 1964. In Comstock, the majority described five factors it considered in holding that the civil-commitment statute was constitutional: (1) the breadth of the Necessary and Proper Clause, (2) the long history of federal involvement in legislating in relation toprison-related mental health statutes, like the one at issue in Comstock, id. at 1958, (3) the sound reasons for the statutes enactment . . ., (4) the statutes accommodation of state interests, and (5) the statutes narrow scope. Id. at 1965. However, the majority opinion demonstrates that these factors are merely ways of rephrasing or implementing the notion that Congress may pass laws rationally related or reasonably adapted to the effectuation of enumerated powers. For example, in discussing the first factor, the Court wrote: We have . . . made clear that, in determining whether the Necessary and Proper Clause grants Congress the legislative authority to enact a particular federal statute, we look to see whether the statute constitutes a means that is rationally related to the implementation of a constitutionally enumerated power. Id. at 1956. Regarding the second factor, the Court explained that the history of federal involvement in an area could not on its own demonstrate a statutes constitutionality; instead, the Court stated that it was a means of analyzing the reasonableness of the relation between the new statute and pre-existing federal interests. Id. at 1958. Similarly, in expounding the third factor, the Court stated that a court should find the reasons for a statute sound if they satisfy the Constitutions insistence that a federal statute represent a rational means for implementing a constitutional grant of legislative authority. Id. at 1962.