United States v. Comstock

In United States v. Comstock, 130 S. Ct. 1949, 176 L. Ed. 2d 878 (2010), the Supreme Court considered whether the Necessary and Proper Clause, U.S. Const. art. I, 8, cl. 18, granted Congress the authority to enact a law that would permit the civil commitment of mentally ill, sexually dangerous prisoners beyond their scheduled release dates. 130 S. Ct. at 1954. The Court focused on a question analogous to that presented here: whether the law must be absolutely necessary before Congress is authorized to act pursuant to the Necessary and Proper Clause. The Court restated the long-standing rule that "the Necessary and Proper Clause makes clear that the Constitution's grants of specific federal legislative authority are accompanied by broad power to enact laws that are 'convenient, or useful' or 'conducive' to the authority's 'beneficial exercise.'" Id. at 1956. To determine whether it was within Congress's power to enact a particular law pursuant to the Necessary and Proper Clause, the Court instead looked "to see whether the statute constituted a means that was rationally related to the implementation of a constitutionally enumerated power." Id. at 1956-57 .