Within our constitutional structure, conflicts over the proper role of the local and Federal governments will inevitably continue to arise. This is illustrated in the dramatic shifts in Tenth Amendment jurisprudence over recent years. In Maryland v. Wirtz (1968), the U.S. Supreme Court held that Congress' regulatory power over the States under the commerce clause was plenary and that the States had no special status in the constitutional structure. In 1976, however, the Supreme Court shifted position and expressly overruled "Wirtz." In National League of Cities v. Usery, the Court revitalized the Tenth Amendment and held that when States acted in their sovereign capacity, they enjoyed a special protection against congressional regulation under the commerce power. Less than 10 years later (1985), the Court reversed itself again. In Garcia v. San Antonio Transit Authority, a divided court overruled its landmark "Usery" decision and held that the States' protection against overreaching by the central government could be found in the political process, but not in the U.S. Constitution. These unusual and dramatic shifts in the Court's jurisprudence are used to support the author's fundamental thesis. He argues that cases which implicate federalism principles are not easy; they do not lend themselves to a simplistic result-oriented approach, but instead require intellectual honesty, careful thought, and an attention to the facts and the law.