On March 5, 1999, the U.S. Fourth Circuit Court of Appeals ruled against Christy Brzonkala, 7-4 in Brzonkala v. Virginia Polytechnic Institute, (Vol.1 of 5, No. 96-1814, 4th Cir. 1999) and ruled the Violence Against Women Act's Civil Rights Remedy as unconstitutional.
Brzonkala v. Virginia Polytechnic was one of the first cases filed under the VAWA (1994) Civil Rights Remedy. Debate focused on whether the U.S. Congress has the power to enact the VAWA Civil Rights Remedy under the Commerce Clause and/or the Equal Protection Clause of the U.S. Fourteenth Amendment. The "Brzonkala v. Virginia Polytechnic" case ruling determines whether or not Brzonkala, a former VPI student, can use federal law enacted under VAWA to sue two men she alleges raped her.
The original 1996 U.S. District Court (Western District of Virginia) decision was appealed to the U.S. Fourth Circuit Court of Appeals in Richmond, Virginia which led to the March 5, 1999 ruling. The U.S. Supreme Court heard arguments on the case on January 11, 2000 and on May 15, 2000 ruled in it was not within the U.S. Congress's power to pass the portions of VAWA 1994 that provided a federal 'civil rights remedy'.