Law School Case Brief
United States v. Comstock - 560 U.S. 126, 130 S. Ct. 1949 (2010)
18 U.S.C.S. § 4248 is reasonably adapted to Congress' 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). Congress could have reasonably concluded that federal inmates who suffer from a mental illness that causes them to have serious difficulty in refraining from sexually violent conduct, 18 U.S.C.S. § 4247(a)(6), would pose an especially high danger to the public if released. And Congress could also have reasonably concluded that a reasonable number of such individuals would likely not be detained by the States if released from federal custody, in part because the Federal Government itself severed their claim to legal residence in any state by incarcerating them in remote federal prisons. Congress' desire to address specific challenges, taken together with its responsibilities as a federal custodian, supports the conclusion that § 4248 satisfies review for means-end rationality, i.e., that it satisfies the United States Constitution's insistence that a federal statute represent a rational means for implementing a constitutional grant of legislative authority.
Federal law allowed a district court to order the civil commitment of a mentally ill, sexually dangerous federal prisoner beyond the date he would otherwise be released. The Government instituted civil-commitment proceedings under § 4248 against respondent Comstock and others, each of whom filed a motion to dismiss the proceedings on the ground that in enacting the statute, Congress exceeded its powers under the Necessary and Proper Clause. Agreeing, the district court granted dismissal, and the United States Court of Appeals for the Fourth Circuit affirmed on the legislative-power ground.
Did Congress exceed the powers granted to it by the Necessary and Proper Clause by enacting § 4248?
The appellate court's judgment was reversed and the case was remanded for further proceedings. The Supreme Court of the United States held that the Necessary and Proper Clause granted Congress broad authority to criminalize conduct, imprison those who engaged in that conduct, and enact laws governing prisons and prisoners in the course of "carrying into Execution" the enumerated powers "vested by" the "Constitution in the Government of the U.S."--authority granted by the Necessary and Proper Clause. Section 4248 was a modest addition to a set of federal prison-related mental-health statutes that had existed for many decades, aside from its focus on sexually dangerous persons. The desire to address the specific challenges identified with mentally ill, sexually dangerous federal prisoners, taken together with the government's responsibilities as a federal custodian with the constitutional power to act to protect communities from the danger its prisoners could pose, satisfied a rational means review. Powers granted by the Necessary and Proper Clause were, by definition, not powers "reserved to the States" under U.S. Const. amend. X, and, § 4248 even required accommodation of state interests. Section 4248 was not too sweeping in scope. From the implied power to punish, the federal civil-commitment power was inferred.
Access the full text case
Not a Lexis Advance subscriber? Try it out for free.
Be Sure You're Prepared for Class