The Rehnquist Court's Commerce Clause cases helped establish the doctrine of "New Federalism." The Court's New Federalism doctrine was focused on reining in congressional powers in order to re-strengthen the powers of the individual states which had been weakened during the New Dea asl era. Members on the Rehnquist Court theorized that by re-apportioning power back to the states, individual liberty was strengthened. In contrast, Erwin Chemerinsky believes that limiting the commerce power as the Rehnquist Court did can only lead to the weakening of individual liberties.