The issue focused on the court's legal theory of criminal liability, or law of civil rights, and its enforcement of federal laws. The Supreme Court had used that legal theory to enforce federal civil rights laws in several cases. But by Justice Antonin Scalia's analysis, it was going too far.

"It is one thing for a State to legislate against illegal conduct; it is quite another to punish those who engage in illegal conduct," he wrote. "We have long held that no individual has a constitutional