Congress, to justify its exercise of – 5 of the 14th amend must prove that there is a rational relationship between a Fed statute and the end sought. The statute must reflect a “congruence and proportionality between the injury to be prevented or remedied and the means adopted to that end.”
The Boerne court held that the challenged statute—designed to prevent state and local governments from infringing on religious freedom—failed this test, as the legislative record failed to show large-scale violations of the constitutional rule the statute was purportedly enforcing.

This decision reflects the Court’s willingness to examine carefully Congress’ asserted grounds for exercising its – 5 authority, and suggest a further cutback in Morgan’s deference to congressional judgment.