New York v. United States - Impact

New York v. United States continued the Tenth-Amendment roller-coaster ride whose highs and lows had been marked by Usery and Garcia. Despite the fact that the Court had only invalidated one of three provisions, some considered the ruling a victory for state sovereignty. To others, it seemed that the alleged movement in favor of the Tenth Amendment, first heralded after Usery, was a revolution that consistently refused to take place. The severability principle implement in New York, however, did help reinforce a notion of flexibility on the Court's part in ruling on disputes between the state and federal governments.