Wickard v. Filburn
317 U.S. 111 (1942)
Rule of Law:
Congress may regulate a purely local and non-commercial activity if, in the aggregate, it exerts a substantial economic effect on interstate commerce.
Facts:
- Roscoe Filburn owned and operated a small farm in Montgomery County, Ohio.
- Filburn maintained a herd of dairy cattle and raised poultry, selling milk, poultry, and eggs.
- It was his practice to sow a small acreage of winter wheat, selling a portion, feeding a portion to his livestock, using some for home consumption, and keeping the rest for future seeding.
- For the 1941 crop, the federal government established a wheat acreage allotment of 11.1 acres for Filburn's farm.
- Filburn sowed 23 acres of wheat, nearly 12 acres over his allotment.
- He harvested 239 bushels of wheat from this excess acreage, which was intended for his own use on the farm.
- Under the Agricultural Adjustment Act, this excess production was subject to a penalty of 49 cents per bushel.
- Filburn refused to pay the penalty or otherwise comply with the Act's requirements for his excess wheat.
Procedural Posture:
- Filburn filed a complaint in a federal trial court against Wickard, the Secretary of Agriculture, and local agricultural committee members.
- Filburn sought to enjoin the government from enforcing the marketing penalty against him.
- The trial court, a three-judge panel, found in favor of Filburn and issued a permanent injunction against the government.
- The Secretary of Agriculture, Wickard, and the other defendants appealed the trial court's decision directly to the Supreme Court of the United States.
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Issue:
Does the Agricultural Adjustment Act of 1938 violate the Commerce Clause by imposing a penalty on a farmer for growing wheat in excess of his allotment, even when the excess wheat is intended for consumption on his own farm?
Opinions:
Majority - Justice Jackson
No. The Agricultural Adjustment Act does not violate the Commerce Clause, because Congress has the power to regulate local activities that, in the aggregate, have a substantial effect on interstate commerce. The court reasoned that although Filburn's individual contribution to the national wheat market was trivial, the cumulative effect of many other farmers similarly situated would be far from trivial. By growing his own wheat for consumption, Filburn supplied a need he would otherwise have fulfilled by purchasing wheat on the open market. This home consumption, therefore, competes with wheat in commerce and exerts a substantial economic effect on interstate commerce by influencing market prices. The court abandoned prior distinctions between 'direct' and 'indirect' effects on commerce, focusing instead on whether the regulated activity, in the aggregate, has a substantial economic effect. Because the national wheat market is subject to federal control, Congress may regulate wheat consumed on the farm where it is grown to effectively control supply and maintain price stability.
Analysis:
This decision represents the broadest interpretation of Congress's power under the Commerce Clause. By establishing the 'aggregation principle,' the court empowered Congress to regulate a vast range of seemingly local, non-commercial activities, provided they could be shown to have a cumulative substantial effect on interstate commerce. This expansive view became the constitutional foundation for numerous federal laws in the following decades, including civil rights and environmental legislation. The case effectively ended the era of using rigid categories like 'production' versus 'commerce' or 'direct' versus 'indirect' effects to limit federal power, solidifying a pragmatic economic-effects test.
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