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The Supreme Court has ushered in the new millennium with a renewed emphasis on federalism-based limits to Congress's regulatory authority in general, and Congress's Section 5 power to enforce the Fourteenth Amendment in particular. In a recent string of cases, the Court has refined and narrowed Section 5's enforcement power in two significant ways.1 First, the Court made clear that Congress lacks the authority to interpret the scope of the Fourteenth Amendment's substantive provisions themselves, and may only "enforce" the judiciary's definition of Fourteenth Amendment violations. 2 Second, the Court embraced a relatively stringent requirement concerning the relationship between means and ends, ruling that "[t]here must be a congruence and proportionality between the injury to be prevented or remedied and the means adopted to that end."3 Within the past three years, the Court has applied these standards governing Congress's Section 5 enforcement to the Religious Freedom Restoration Act,4 the Patent and Plant Variety Protection Remedy Clarification Act,5 and the Age Discrimination in Employment Act.6 And just last month, the Court applied these same standards to invalidate the Violence Against Women Act in United States v. Morrison.7