S-4243-118
Became Public Law No: 118-150.
What it does
This law directs the U.S. government to posthumously award a Congressional Gold Medal to Shirley Chisholm, recognizing her political achievements and her historic election as the first African American woman in Congress. The gold medal would be displayed at the Smithsonian Institution. The law also authorizes the U.S. Mint to produce and sell bronze duplicate medals to the public.
Who benefits
The Smithsonian Institution, which receives and displays the medal as a permanent artifact. Members of the public who wish to purchase bronze duplicate medals. Historians, educators, and museum visitors who gain access to a federally recognized commemoration of Chisholm's legacy. Chisholm's family and community members who may find recognition in the honor.
Who is hurt
There are no significant groups directly harmed by this legislation. There is a minor cost to the federal government for the production of the gold medal, which is borne by taxpayers broadly, though the cost is negligible. The bronze duplicate sales are intended to offset production costs.
Supporters argue
Supporters argue that the Congressional Gold Medal is Congress's highest civilian honor, and Shirley Chisholm's achievements — becoming the first African American woman elected to Congress in 1968 and the first to seek a major-party presidential nomination in 1972 — represent a landmark chapter in American political history. They contend that formally recognizing her contributions preserves an important historical record, educates future generations, and affirms that trailblazing public service merits the nation's highest recognition regardless of when it occurred. Placing the medal at the Smithsonian ensures broad, lasting public access to this piece of history.
Opponents argue
Opponents argue that while Chisholm's historical significance is not in dispute, Congress has awarded the Congressional Gold Medal with increasing frequency, raising questions about whether the honor retains its distinction when granted broadly. They contend that legislative floor time and administrative resources spent on commemorative acts could be directed toward substantive policy matters. Some may also argue that decisions about which historical figures receive the nation's highest civilian honor involve inherently subjective value judgments that Congress is not best positioned to make uniformly or consistently.
Constitutional context
Congress's authority to award honorary medals derives from its broad implied powers under the Necessary and Proper Clause (Article I, Section 8). The spending involved is minimal and does not implicate major Commerce Clause or Takings Clause questions. No significant case law — including Wickard v. Filburn, United States v. Lopez, or West Virginia v. EPA — is directly relevant, as this bill does not regulate commerce, delegate agency authority, or affect property rights. The act raises no active constitutional tensions.
Checks and balances
This law involves a straightforward exercise of congressional authority. Congress directs the executive branch (specifically the U.S. Mint, an arm of the Treasury Department) to produce the medal. No new regulatory authority is created, no agency discretion is expanded, and no branch gains meaningful new power relative to another.
Historical precedent
Congress has awarded the Congressional Gold Medal to numerous historical figures, including Rosa Parks (1999), Martin Luther King Jr. and Coretta Scott King (2004), and the Women Airforce Service Pilots (2009), establishing a long pattern of posthumous commemorative awards.