This article focuses on the U.S. Supreme
Court's recent decision, in "U.S. v
Morrison", to strike down s.13,981 of the
Violence Against Women Act (VAWA) for
violating the Commerce Clause and the
State Action Doctrine. VAWA s.13,981
provides a civil remedy for victims of
gender-motivated violence against their
abusers. The article takes the position
that the Supreme Court should have upheld
the private right of action. The article
discusses the implications of this
decision and draws links to the United
States' international obligations under