Major Cases

Noting that this was an issue of first impression in this Circuit and any other, the Court held that the defendant “substantially affected” interstate commerce by assaulting the victim and interfering with the victim’s packaging and shipping of products intended for interstate commerce. The Court cited the low standard for invoking jurisdiction under the Commerce Clause, which applies to violent conduct that has even a “minimal effect” on interstate commerce.

The Court affirmed the defendant’s conviction for a DUI after police took his blood while he was passed out, with a plurality of the  Court holding that conducting a blood test on a defendant while he is passed out is permissible under the “exigent circumstance” exception to the Fourth Amendment’s warrant requirement.