Wickard v. Filburn
"Wickard v. Filburn" is a landmark Supreme Court case decided in 1942 that significantly shaped the interpretation of the Commerce Clause in the United States Constitution. The case arose from the Agricultural Adjustment Act of 1938, which established production quotas for wheat to stabilize prices during the Great Depression. Roscoe Filburn, a small farmer, exceeded his wheat quota by growing grain for personal consumption and livestock feed, which led to penalties from the federal government. Despite Filburn's activities being local and not directly involved in interstate commerce, the Supreme Court ruled unanimously against him, arguing that his decisions impacted the national market by reducing demand for wheat from other producers.
This ruling affirmed the federal government's broad powers to regulate economic activity, even if it is local in nature, on the grounds that such activities can cumulatively affect interstate commerce. The decision was pivotal in reinforcing the legal foundations of New Deal legislation and highlighted the expansive view of federal authority in economic regulation. The case remains significant in discussions about the limits of federal power and the scope of the Commerce Clause in American law.
Wickard v. Filburn
Date: November 9, 1942
Citation: 317 U.S. 111
Issue: Commerce clause
Significance: The Supreme Court expanded the definition of interstate commerce to justify federal regulation supporting much New Deal legislation.
The Agricultural Adjustment Act of 1938, part of the New Deal legislation, placed quotas on the amount of grain that could be produced. Roscoe Filburn was a small farmer who raised wheat for his own consumption and to feed his own livestock. In 1941 he exceeded his quota and was penalized by the federal government. Although Filburn did not engage in any commerce beyond his locality and never across state lines, the Supreme Court unanimously ruled against him, arguing that his own consumption reduced the sales others would have made to him across state lines and therefore affected interstate commerce. The Court upheld the 1938 act and, by implication, much New Deal legislation. In the early 1930’s, the Court’s reluctance to approve New Deal legislation led Franklin D. Roosevelt to attempt a Court-packing plan; however, he eventually appointed enough members (and persuaded others to change their minds) to control the Court. This complete control was evident in this unanimous opinion. With interstate commerce so broadly defined there was virtually no limit to the power of the federal government to regulate commerce.
