The U.S. Supreme Court's Supremacy Clause jurisprudence has reached a confusing junction. The Court recently declined to say whether the Supremacy Clause confers a cause of action for federal court litigants. As a result, lower courts and litigants are caught between conflicting doctrines: one that suggests and one that denies that the Supremacy Clause confers causes of action. Neither line of cases definitively answers the question. A cause of action is necessary for a federal court plaintiff

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... o bring suit. This Note explores whether potential plaintiffs should be able to rely on the Supremacy Clause when applicable federal law does not otherwise confer a cause of action. Navigating the history of the Supremacy Clause, the contours of dueling lines of precedent, and policy ramifications, the Note concludes that, in the midst of the confusion, state defendants have a strong argument that the Supremacy Clause does not confer plaintiffs a cause of action. 1009 25 See infra notes 196-270 and accompanying text. 26 See infra notes 38-40, 218-242 and accompanying text. 27 See U.S. Const. arts. I, II, III (separating power among three major branches of government: the legislature, the executive, and the judiciary). 28 See infra notes 257-270 and accompanying text. 29 See infra notes 36-63 and accompanying text. 30 See infra notes 64-89 and accompanying text. 31 See infra notes 64-89 and accompanying text. 32 See infra notes 64-89 and accompanying text. 33 See infra notes 90-189 and accompanying text. 34 See infra notes 90-189 and accompanying text. 35 See infra notes 190-270 and accompanying text.