In recent years, the Court invalidated two con- gressional statutes that attempted to regulate non- economic activities. In United States v. Lopez (1995), it struck down the Gun-Free School Zones Act, which attempted to reach the activity of possessing a gun within a thousand feet of a school. In United States v. Morrison (2000), it invalidated part of the Violence Against Women Act, which regulated gen- der-motivated violence. Because the Court found the regulated activity in each case to be non- economic, it was outside the reach of Congress’s Commerce power, regardless of its effect on inter- state commerce. To uphold the insurance purchase mandate, the Supreme Court would have to concede.
