In his opinion, no more than this was required to find sufficient supporting power for the challenged law under the Commerce Clause, and he consequently believed that the Court of Appeals had erred and should be reversed. In his dissent, Justice Souter warned that the distinction between "commercial" and "non-commercial" activity was not tenable. He echoed the "rational basis" theme of the Breyer dissent. Justice Stevens, in his dissent, iterated his agreement with the Breyer dissent that found ample congressional power under the Commerce Clause to regulate the possession of firearms in schools, in the same way that Congress may act to protect the school environment from alcohol or asbestos. He also agreed with Justice Souter's "exposition of the radical character of the Court's holding and its kinship with the discredited, pre-Depression version of substantive due process." "Lopez" was the first case since 1937 in which the Court held that Congress had exceeded its power to legislate under the Commerce Clause. It raised serious questions as to how far the Court might be willing to go in implementing judicial safeguards against federal encroachments on state sovereignty. This precedent takes special significance in cases where the federal government is attempting to limit private conduct. Commentators are still postulating its possible effects on other established federal laws enacted pursuant to the Commerce Power. The argument can be made that this significant limiting of federal power is necessary to establish a greater threshold for governmental accountability and revitalizes the role of the states in public policymaking. This can also be ascribed to new legislation that makes open carry in schools legal in some Texas jurisdictions. "United States v. Lopez" has been followed by the Supreme Court in limiting Congress' power under the Commerce Clause in the 1999 case of "United States v. Morrison" and under other enumerated powers in the 2001 case of "Solid Waste Agency of Northern Cook County v. United States Army Corps of Engineers" ("SWANCC"). Following the "Lopez" decision, Congress rewrote the Gun Free School Zones Act of 1990 with the necessary interstate-commerce "hook" used in other Federal Gun Laws. The revised Federal Gun Free School Zones Act is currently in effect and has been upheld by several United States Appellate Courts. None of the convictions occurring under the revised law have been overturned as a result of the "Lopez" decision.