Wickard v. Fillburn
317 U.S. 111 (1942)
Constitutional Topic Areas:
Article 1 §8 Clause 3 “Commerce Clause”, 5th Amendment “Due Process Clause”, Federalism, Appellate Jurisdiction, Substantive Due Process
Case Facts:
In the 1930s battle against the great depression, Congress enacted the New Deal under President Roosevelt. Within the New Deal, the Agricultural Adjustment Act of 1938 became law, imposing a maximum amount of wheat any single farmer could produce in an effort to quash rising supply and low demand for wheat at the time. Filburn owned a small dairy farm as his main source of income, but grew wheat on his farm for livestock feed, as well as home use. As a result of growing more wheat than his quota stipulated, Filburn was fined. Filburn sued Secretary of Agriculture, Claude Wickard, arguing Congress’ exceeded its authority under the commerce clause by regulating his production of wheat which was never intended to be injected into the stream of interstate commerce. The district court sided with Filburn, declaring the Agricultural Adjustment Act to be unconstitutional. An appeal to the Supreme Court was made following the ruling of the district court.
Questions:
1. Do Congress’ commerce clause powers allow it to regulate purely intrastate activities?
Holding:
1. Yes
Legal Reasoning: Justice R.H. Jackson (Unanimous)
1. The production of wheat, even if not sold on the market, still affects interstate commerce
2. The aggregation doctrine was applied, asserting that if Congress could not regulate small amounts of wheat grown for home use, then the aggregate of wheat production throughout the nation could effectively escape congressional regulation as well
3. If Filburn couldn’t grow his own wheat, he must purchase it on the open market, effectively increasing demand and lowering supply, which was the goal of the Agricultural Adjustment Act in the first place
Significance:
This case again broadened Congress’ scope of power relative to the states Utilizing the aggregation doctrine, the Supreme Court effectively broadened Congress’ commerce clause powers by creating a strong precedent on how Congress may regulate purely intrastate activities
Reflection:
Wickard v. Filburn’s precedent still stands, as the Supreme Court has applied this precedent in modern jurisprudence where Congress’ commerce clause powers are challenged. Overall, Wickard strengthened the power of the federal government
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