Wickard v. Filburn
|Wickard v. Filburn|
|Court||U.S. Supreme Court|
|Citation||317 U.S. 111 (1942)|
Commerce Clause (Article I, §8)
- Should production be considered part of interstate commerce or should it be considered a separate, independent activity? The basic constitutional question is can an activity of a "local character" that might indirectly affect interstate commerce be regulated under the Commerce Clause?
- Since Filburn argues that the excess wheat was produced for his own private consumption and therefore never entered the stream of commerce, can the U.S. government still regulate his activities within the scope of the Commerce Clause?
- Does the federal government's regulation of intrastate activities, such as the production and consumption of wheat, violate the principles of the 10th amendment? Are the internal police powers delegated to individual states being trampled upon by the U.S. Congress?
In a unanimous decision, the Supreme Court upheld the constitutionality of the 1938 Agricultural Adjustment Act, reversing the ruling of a lower court.SCOTUS announces that Congress has the power to impose a production quota on wheat.
- The court's opinion stated that Congress had the authority to regulate wholly intrastate, non-commercial activity assuming that such activity would have a serious effect on interstate commerce.
- Although Filburn argued that the excess wheat he produced was intended entirely for his own consumption, Justice Jackson points out that Filburn would have otherwise had to buy that wheat on the open market. While the actions of one farmer are insignificant, Justice Jackson reasoned that if thousands of other farmers took the same actions as Filburn, then interstate commerce would be significantly affected. Because of lower demand from these farmers for wheat, the price of wheat would be artificially low.
- Justice Jackson quotes from Chief Justice Stone's opinion in U.S. v. Darby, "The power of Congress over interstate commerce is plenary and complete in itself, may be exercised to its utmost extent, and acknowledges no limitations other than are prescribed in the Constitution... It follows that no form of state activity can constitutionally thwart the regulatory power granted by the commerce clause to Congress."
The decision in Wickard v. Filburn marked the end to any limits on Congress's commerce clause powers. Their authority to regulate now extended to ostensibly intrastate activities such as consumption and production. From this point forward, the Supreme Court went more than a half century before it ruled against the federal government in an interstate commerce case.
- United States v. Darby Lumber Co. regarding (1) maximum hours & (2) minimum wages that have an effect on interstate commerce.