Wickard v. Filburn
| Wickard v. Filburn | |
|---|---|
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| Argued May 4, 1942 Reargued October 12, 1942 Decided November 9, 1942 |
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| Full case name | Claude R. Wickard, Secretary of Agriculture, et al. v. Roscoe C. Filburn |
| Citations | 317 U.S. 111 (more)
63 S. Ct. 82; 87 L. Ed. 122; 1942 U.S. LEXIS 1046
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| Prior history | Injunction granted to plaintiff, Filburn v. Helke, 43 F. Supp. 1017 (S.D. Ohio 1942) |
| Holding | |
| Production quotas under the Agricultural Adjustment Act of 1938 were constitutionally applied to agricultural production that was consumed purely intrastate, because its effect upon interstate commerce placed it within the power of Congress to regulate under the Commerce Clause. Southern District of Ohio reversed. | |
| Court membership | |
| Case opinions | |
| Majority | Jackson, joined by unanimous |
| Laws applied | |
| U.S. Const. amends. I, V; 7 U.S.C. § 1281, et. seq. (1941) (Agricultural Adjustment Act of 1938) | |
Wickard v. Filburn, 317 U.S. 111 (1942), was a United States Supreme Court decision that dramatically increased the regulatory power of the federal government. It was a test case that was heard shortly after the United States had entered World War II. The goal of the business interests that financed the legal challenge all the way to the Supreme Court was to convince the Court to declare the entire federal crop support program unconstitutional and thereby end it. The Filburn decision supported what Congress had done, and said the Constitution enabled congressional regulation that included economic activity that was only indirectly related to interstate commerce.
An Ohio farmer, Roscoe Filburn, was growing wheat to feed animals on his own farm. The U.S. government had established limits on wheat production based on acreage owned by a farmer, in order to stabilize wheat prices and supplies. In 1941 Filburn grew more than the limits permitted and he was ordered to pay a penalty of $117.11. He claimed his wheat was not sold in interstate commerce and so the penalty could not apply to him. The Supreme Court stated "The intended disposition of the crop here involved has not been expressly stated" and later "Whether the subject of the regulation in question was 'production', 'consumption', or 'marketing' is, therefore, not material for purposes of deciding the question of federal power before us ... [b]ut even if appellee's activity be local and though it may not be regarded as commerce, it may still, whatever its nature, be reached by Congress if it exerts a substantial economic effect on interstate commerce and this irrespective of whether such effect is what might at some earlier time have been defined as 'direct' or 'indirect'."
The Supreme Court interpreted the United States Constitution's Commerce Clause under Article 1 Section 8, which permits the United States Congress "to regulate Commerce with foreign Nations, and among the several States, and with the Indian Tribes." The Court decided that Filburn's wheat growing activities reduced the amount of wheat he would buy for animal feed on the open market, which is traded nationally (interstate), and is therefore within the purview of the Commerce Clause. Although Filburn's relatively small amount of production of more wheat than he was allotted would not affect interstate commerce itself, the cumulative actions of thousands of other farmers just like Filburn would certainly become substantial. Therefore, according to the court, Filburn's production could be regulated by the federal government.
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