In the fall of 1994, Virginia Tech student Christy Brzonkala claimed that two of the school's football players, Antonio Morrison and James Crawford, repeatedly raped and assaulted her. After a state grand jury failed to find sufficient evidence with which to charge either Morrison or Crawford with the crime, Brzonkala filed suit under the federal Violence Against Women Act. Her suit concerned a provision ensuring a federal civil remedy for victims of violence even in the absence of criminal charges. Cato's brief, joined by the Institute for Justice, stresses that the limited scope of Congress's power, as constrained by the Commerce Clause, denies Congress the power to pass VAWA. Moreover, the Fourteenth Amendment authorizes the courts and Congress to take measures against civil rights violations by states, not by private individuals or institutions, so the actions of Morrison and Crawford do not justify federal intervention.