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Morrison 7 are perhaps the best know of these. Its criminal proscription contained no commerce element; it did not, for example, outlaw possession of a firearm, which had been transported in interstate commerce, within 1000 feet of a school. Moreover, the Act lacked the kind of explicit restraints or guidelines that might have confined its application to instances more clearly within the Commerce power. 13 The Court has extended this principle by holding that Congress may not circumvent the prohibition on commandeering a States regulatory processes by conscripting the State s officers directly. They did this because of an increase in cost productuion. Boyd, 149.3d 1062, 1065-66 (10th Cir.