Wickard v. Filburn facts for kids
Quick facts for kids Wickard v. Filburn |
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| Argued May 4, 1942 Reargued October 12, 1942 Decided November 9, 1942 |
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| 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
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| Prior history | 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. | |
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| 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) | |
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Overruled by
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| (partially) United States v. Lopez (1995) | |
Wickard v. Filburn, a case from 1942, is a very important decision by the Supreme Court of the United States. It greatly increased the power of the U.S. federal government to control economic activities. This case is still seen as one of the most significant rulings about the New Deal, a series of programs and reforms in the 1930s. It set a rule for how broadly the U.S. Constitution's Commerce Clause could be understood for many years. The main goal of the lawsuit was to stop the entire federal program that supported crop prices, by saying it was against the Constitution.
The case involved Roscoe Filburn, a farmer in Ohio. He was growing wheat to feed the animals on his own farm. The U.S. government had set limits on how much wheat farmers could grow. These limits were based on the size of a farmer's land. The idea was to keep wheat prices and supplies stable across the country. Filburn grew more wheat than he was allowed, so he was told to pay a fine. He argued that because he didn't sell his wheat, it wasn't "commerce." He especially argued it wasn't "interstate commerce," which the Constitution describes as trade "among the several states." The Supreme Court disagreed with him. They said that even if an activity is local and not seen as commerce, Congress can still regulate it if it has a big economic effect on interstate commerce.
The Supreme Court looked closely at the Constitution's Commerce Clause. This clause, found in Article I, Section 8, allows the U.S. Congress "to regulate Commerce with foreign Nations, and among the several States, and with the Indian Tribes." The Court decided that when Filburn grew his own wheat, it meant he wouldn't buy wheat from the open market. Wheat on the open market is traded nationally, which makes it interstate commerce. Even though Filburn's small amount of extra wheat wouldn't affect national trade much by itself, the Court reasoned that if thousands of other farmers did the same thing, the total effect would be huge. Because of this, the Court ruled that the federal government could control how much wheat Filburn grew.
Why the Case Happened: The Agricultural Adjustment Act
The Agricultural Adjustment Act of 1938 was a law that limited how much land farmers could use to grow wheat. Its main goal was to keep the price of wheat stable in the national market. It did this by controlling the total amount of wheat grown. Congress believed that big changes in how much wheat was available and how much people wanted it were causing wheat prices to swing wildly. These price swings were seen as bad for the U.S. farming economy.
The Supreme Court's decision mentioned that both sides in the case agreed on the economic problems that led to this law. For example, the amount of wheat the U.S. exported had dropped a lot. This left a large amount of extra wheat in the country. This surplus caused problems in markets, like crowded railroad cars and full storage elevators. Many countries, including the U.S., tried to protect their farmers from these world market changes. Without government rules, the price of wheat in the U.S. would have been much lower, closer to the world market price.
Roscoe Filburn was a farmer near what is now Dayton, Ohio. He admitted that he grew more wheat than the law allowed. However, he insisted that this extra wheat was only for his own use on his farm. Since it was never sold or traded, he argued it wasn't part of commerce at all. Therefore, he believed the federal government couldn't regulate it under the Commerce Clause.
In July 1940, Filburn was told his wheat limit for 1941 was about 11.1 acres. This would normally produce about 20.1 bushels of wheat per acre. He received this notice before planting his 1941 crop and again before harvesting it. Despite these warnings, Filburn planted 23 acres. He harvested 239 more bushels than he was allowed from his extra 11.9 acres.
The Federal District Court first sided with Filburn. Part of their decision was about how the U.S. Secretary of Agriculture had encouraged farmers to vote for the wheat quota. The District Court thought the Secretary's actions were wrong. The government then appealed to the Supreme Court. The Supreme Court disagreed with the District Court's view on the Secretary's campaign methods. The higher court then went on to support the law under the Commerce Clause.
By the time this case reached the Supreme Court, eight of the nine justices had been chosen by President Franklin D. Roosevelt. He was the leader behind the New Deal laws. Also, the case was heard during World War II, shortly after the attack on Pearl Harbor made the United States join the war. The Court's decision supported the President's goals. It ruled that the Constitution allowed the federal government to control economic activities that were only indirectly connected to trade between states.
The Supreme Court's Decision
The main reason for the Agricultural Adjustment Act was to keep wheat prices stable across the country. The federal government has the power to regulate trade between states because of the Commerce Clause in the Constitution. In this case, the Court unanimously decided that the power to control prices in trade was naturally part of the power to regulate trade itself.
Filburn argued that since his extra wheat was only for his own use, his wheat production couldn't be regulated by the Commerce Clause. The Supreme Court rejected this argument. They reasoned that if Filburn had not grown his own wheat, he would have had to buy wheat from the open market.
The Court said that this effect on interstate commerce might not be big from Filburn's actions alone. However, if thousands of other farmers did the same thing as Filburn, the total effect would become very significant.
So, Congress could regulate activities that happened entirely within one state and were not for selling. This was allowed if these activities, when looked at all together, would have a big effect on trade between states. This was true even if each individual action seemed small.
Some of the arguments in the case focused on older decisions. These decisions tried to figure out if a business activity was local or not. Justice Robert H. Jackson wrote the Court's decision. He said that this old way of thinking was too simple.
He explained that the question was not how to label an activity, like "production" or "consumption." Instead, the real question was whether the activity "exerts a substantial economic effect on interstate commerce."
The Court held that regulating the local growing of wheat was logically connected to Congress's goal. That goal was to stabilize prices by limiting the total amount of wheat grown and used. The Court believed that a large amount of wheat grown and eaten at home would greatly affect prices and market conditions. This home-grown wheat, in a way, competes with wheat that is sold in trade. The Court was sure that if home-grown wheat was completely outside the rules, it would make it much harder for the government to achieve its goal of increasing trade prices.
What Happened After Wickard
The Wickard decision marked a long period where the Supreme Court largely agreed with the U.S. Congress's use of its Commerce Clause powers. This continued until the 1990s. However, the Court's own decision in Wickard pointed out that voters and elections are important for stopping Congress from misusing its power.
According to legal experts, Wickard and other New Deal decisions gave Congress almost unlimited power to regulate private economic activity.
This situation changed with the case of United States v. Lopez in 1995. This was the first time in 60 years that the Court said a federal law was unconstitutional because it went beyond Congress's power under the Commerce Clause. The Lopez opinion described Wickard as "perhaps the most far reaching example of Commerce Clause authority over intrastate commerce." It also said that Wickard "greatly expanded the authority of Congress beyond what is defined in the Constitution under that Clause."
In Lopez, the Court ruled that Congress had broad power to make laws under the Commerce Clause. However, this power was limited. It did not extend so far as to allow Congress to regulate carrying handguns, especially when there was no proof that carrying them affected the economy on a huge scale. Later, in the 2000 case United States v. Morrison, the Court ruled that Congress could not make such laws even if there was evidence of a total effect.
In 2012, Wickard was a key part of the arguments in the cases National Federation of Independent Business v. Sebelius and Florida v. United States Department of Health and Human Services. These cases were about whether the individual mandate of the Affordable Care Act was constitutional. Both sides, those who supported the mandate and those who opposed it, claimed that Wickard supported their arguments.
