FN3.   See, for example, Brzonkala v. Virginia Polytechnic Institute, 169 F.3d 820 (4th Cir. 1999)(en banc), aff’d, U.S. v. Morrison, 529 U.S. 598 (2000), in which a student allegedly raped by a football player sued both him and the institution under the federal Violence Against Women Act (42 U.S.C. 13981).  The U.S. Supreme Court invalidated the law, ruling that violence against women does not have a substantial adverse impact on interstate commerce and thus was beyond Congress’ authority to legislate.