US v. Morrison (2020)The Supreme Court considered the constitutionality of 42 U.S.C. §13981, part of the Violence Against Women Act, which provided a federal civil cause of action to any victim of gender-motivated violence. Analyzing §13981 according to the framework delineated in United States v. Lopez, the Court held that gender motivated violence is not a commercial activity and is not substantially connected to interstate commerce, rendering the statute invalid under the Commerce Clause. The Court further determined that, since it targeted private actors, §13981 was outside the scope of the Fourteenth Amendment.