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I would like to question the categorization of Hammer as a Tenth Amendment case. I read Hammer as falling primarily into a group of cases that sought to apply distinctions from dormant commerce clause jurisprudence into exercise of the commerce clause power by Congress. It seems to me that the opinion devotes a single line to the Tenth Amendment, and virtually the rest of the opinion to making distinctions between regulating the transport of goods across state lines, on the one hand, and regulating the manufacturing process.
