Significance
Katzenbach v. Morgan is a prime example of judicial deference to Congressional authority, and allowed Congress great latitude in use of Section 5. Thirty-one years after Katzenbach, the Supreme Court revisited the "ratchet" interpretation, in the case of City of Boerne v. Flores (1997). The Boerne Court stated: "This is not a necessary interpretation, however, or even the best one." By striking down the Religious Freedom Restoration Act, the Court addressed the separation of powers concerns voiced earlier by Justice Harlan in Morgan.
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“History is the interpretation of the significance that the past has for us.”
—Johan Huizinga (18721945)