Wickard v. Filburn

Following is the case brief for Wickard v. Filburn, 317 U.S. 111 (1942)

Case Summary of Wickard v. Filburn:

  • The Agriculture Adjustment Act of 1938 and its 1941 amendments, established quotas for wheat production.  Penalties were imposed if a farmer exceeded the quotas.
  • The Act was passed under Congress’ Commerce Clause power.
  • Roscoe Filburn, produced twice as much wheat than the quota allowed.  He was fined under the Act.
  • Filburn challenged the fine in Federal District Court.  He claimed that the excess wheat could not be regulated because it was for private consumption (to feed his animals, etc.) and not to sell on the market.  He noted that his wheat was never in commerce, and therefore could not effect interstate commerce.
  • The Federal District Court agreed with Filburn.
  • The U.S. Supreme Court reversed.  It held that Filburn’s excess wheat production for private use meant that he would not go to market to buy wheat for private use.  While that impact may be trivial, if thousands of farmers acted like Filburn, then there would be a substantial impact on interstate commerce.  Therefore, Congress’ power to regulate is proper here, even though Filburn’s excess wheat production was intrastate and non-commercial.

Wickard v. Filburn Case Brief

Statement of the Facts:

As part of President Franklin D. Roosevelt’s New Deal programs, Congress passed the Agricultural Adjustment Act of 1938 in response to the notion that great fluctuations in the price of wheat was damaging to the U.S. economy.  The purpose of the Act was to stabilize the price of wheat by controlling the amount of wheat that was produced in the United States.  Thus, the Act established quotas on how much wheat a farmer could produce, and enforced penalties on those farmers who produced wheat in excess of their quota.  The Act was passed under Congress’ Commerce Power.

Roscoe Filburn, an Ohio farmer, admitted to producing more than double the amount of wheat that the quota permitted.  He was fined about $117 for the infraction.  Filburn, however, challenged the fine in Federal District Court.  He claimed that the excess wheat was for private consumption (to feed the animals on his farm, etc.).  Because the wheat never entered commerce at all, much less interstate commerce, his wheat production was not subject to regulation under the Commerce Clause.

Procedural History:

  • The District Court agreed with Filburn. The District Court emphasized that the Secretary of Agriculture’s failure to mention increased penalties in his speech regarding the 1941 amendments to the Act, invalidated application of the Act.
  • The U.S. Supreme Court decide to hear the Secretary of Agriculture’s appeal.

Issue and Holding:

If purely private, intrastate activity could have a substantial impact on interstate commerce, can Congress regulate it under the Commerce Power?  Yes.

Judgment:

The decision of the District Court for the Southern District of Ohio is reversed.

Rule of Law or Legal Principle Applied:

Congress, under the Commerce Clause, can regulate non-commercial, intrastate activity if such activity, taken in the aggregate, would substantially impact interstate commerce.

Reasoning:

The power to regulate the price of something is inherent in Congress’ power to regulate commerce.  Here, Filburn produced wheat in excess of quotas for private consumption.  Had he not produced that extra wheat, he would have purchased wheat on the open market.  While Filburn supplanting his excess wheat for wheat on the market is not substantial by itself, the cumulative actions of thousands of farmers doing what Filburn did would substantially impact interstate commerce.

Accordingly, Congress can regulate wholly intrastate, non-commercial activity if such activity, taken in the aggregate, would have a substantial effect on interstate commerce.  That is true even if the individual effects are trivial.

Significance:

Wickard v. Filburn is a landmark Commerce Clause case.  The case dramatically increased the federal government’s regulatory power under the Commerce Clause.  In fact, it set the precedent for use of the Commerce Power for decades to come.  Up until the 1990s, the Court was highly deferential to Congress’ use of the Commerce Power, allowing regulation of a great deal of private economic activity.

In 1995, however, the Court decided United States v. Lopez, which was the first time in decades that the Court decided that Congress exceeded its Commerce Clause authority.  The Court found that the Commerce Power did not extend to regulating the carrying of handguns in certain places.  Wickard factored prominently in the Court’s decision.  More recently, Wickard has been cited in cases involving the regulation of home-grown medical marijuana, and in the Court cases regarding the constitutionality of the Affordable Care Act.

Student Resources:

Read the Full Court Opinion

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