Wickard v. Filburn

Wickard v. Filburn
Supreme Court of the United States
Argued May 4, 1942 Reargued October 12, 1942 Decided November 9, 1942
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
Decision	Opinion
Case history
Prior	Injunction granted to plaintiff, Filburn v. Helke, 43 F. Supp. 1017 (S.D. Ohio 1942); probable jurisdiction noted, 62 S. Ct. 919 (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.
Court membership
Chief Justice Harlan F. Stone Associate Justices Owen Roberts · Hugo Black Stanley F. Reed · Felix Frankfurter William O. Douglas · Frank Murphy Robert H. Jackson
Case opinion
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 landmark United States Supreme Court decision that dramatically increased the regulatory power of the federal government. It remains as one of the most important and far-reaching cases concerning the New Deal, and it set a precedent for an expansive reading of the U.S. Constitution's Commerce Clause for decades to come. The goal of the legal challenge was to end the entire federal crop support program by declaring it unconstitutional.^[1]

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 the acreage owned by a farmer, to stabilize wheat prices and supplies. Filburn grew more than was permitted and so was ordered to pay a penalty. In response, he said that because his wheat was not sold, it could not be regulated as commerce, let alone "interstate" commerce (described in the Constitution as "Commerce ... among the several states"). The Supreme Court disagreed: "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. ... But 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'."^[2]

The Supreme Court interpreted the Constitution's Commerce Clause, in Article I, Section 8, of the Constitution, which permits the U.S. 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, is thus interstate, and is therefore within the scope 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 like Filburn would become substantial. Therefore, the Court decided that the federal government could regulate Filburn's production.^[3]