under the necessary and proper clause, is at an end.

By the cooperative conception of the federal relationship the States and
the National Government are regarded as mutually complementary parts of
a single governmental mechanism all of whose powers are intended to
realize the current purposes of government according to their
applicability to the problem in hand. This is the conception on which
the recent social and economic legislation professes to rest. It is the
conception which the Court invokes throughout its decisions in
sustaining the Social Security Act of 1935 and supplementary state
legislation. It is the conception which underlies congressional
legislation of recent years making certain crimes against the States,
like theft, racketeering, kidnapping, crimes also against the National
Government whenever the offender extends his activities beyond state
boundary lines. The usually cited constitutional justification for such
legislation is that which was advanced forty years ago in the above
quoted Hoke Case.[20]

It has been argued that the cooperative conception of the federal
relationship, especially as it is realized in the policy of federal
subventions to the States, tends to break down state initiative and to
devitalize state policies. Actually, its effect has often been just the
contrary, and for the reason pointed out by Justice Cardozo in Helvering
_v._ Davis,[21] decided in 1937, namely, that the States, competing as
they do with one another to attract investors, have not been able to
embark separately upon expensive programs of relief and social
insurance. Another great objection to Cooperative Federalism is more
difficult to meet. This is, that Cooperative Federalism invites further
aggrandizement of national power. Unquestionably it does, for when two
cooperate, it is the stronger member of the combination who usually