court’s] duty is to adopt the latter.” Jones, 529 U.S. at 857, 120 S.Ct. 1904 (quotation omitted). See also United States v. Bass, 404 U.S. 336, 349, 92 S.Ct. 515, 30 L.Ed.2d 488 (1971) (applying this principle, as in Jones, to a setting where one construction of a statute would “define as a federal crime conduct readily denounced as criminal by the States”). In applying this constitutional-avoidance principle to the arson of a private residence, Jones emphasized “that the area was one of traditional state concern and that the legislation [was] aimed at activity in which neither the actors nor their conduct has a commercial character.” 529 U.S. at 858, 120 S.Ct. 1904 (citation and quotation omitted). See United States v. Lopez, 514 U.S. 549, 567, 115 S.Ct. 1624, 131 L.Ed.2d 626 (1995) (<HOLDING>). Jones likewise teaches that federal courts
holding that statute which prohibited gun possession near a school zone exceeded congresss authority under the commerce clause because the statute did not regulate activity that had a substantial effect on interstate commerce holding that gunfree school zones act of 1990 which proscribed possession of a firearm within 1000 feet of a school exceeded congressional authority under commerce clause because it reached conduct that did not substantially affect or have a meaningful connection with interstate commerce holding that the gunfree school zone act exceeds congresss authority to regulate commerce holding that the gunfree school zones act exceeds congress power under the commerce clause holding that 42 usc  13981 exceeds congresss authority under the commerce clause