Summary of Wickard v. Filburn
Citation: 317 U.S. 111
Relevant Facts: Filburn was the owner of a small Ohio farm. He was provided a wheat acreage allotment of 11.1 acres, granted by the Department of Agriculture; the federal government had authorized the DOA to set production quotas for wheat. Filburn harvested nearly twice his permitted allotment. He asserted that he wanted to use the excess for personal use (feed for his poultry and livestock) rather than sell it. Filburn was subsequently penalized for his overproduction. Filburn challenged his penalty, arguing that because it was for personal use it did not relate to commercial activity.
Issues: The legal question presented was whether the amendment under which Filburn was restricted to wheat quotas and then penalized over when he exceeded them was unconstitutional because Congress lack the authority to regulate local activities.
Holding: The Supreme Court held that the amendment was not unconstitutional.
Reasoning: The Court unanimously reasoned that the highlighted act regulated both production and consumption, which are inherently local issues. However, the Court reasoned per Justice Jackson that although an activity may be local and not necessarily part of commercial activity, “it may still, whatever its nature, be reached by Congress if it exerts a substantial economic effect on interstate commerce, and this irrespective of whether such effect is what might at some earlier time have been defined as ‘direct’ or ‘indirect.'”
Conclusion: This case was significant because the Court was perceived to have expanded Congressional powers to intervene in local activities even though those activities may not be explicitly commercial.