Wickard v. Filburn

317 U.S. 111, 63 S. Ct. 82 · Supreme Court of the United States · 1942

Constitutional Law Assigned in 23 casebooks

Case brief summary

Rule

Congress can regulate even small, local, non-commercial activity under its interstate commerce power if that activity, combined across many people, significantly affects the national market for a product.

Facts

An Ohio farmer grew wheat to sell, feed his animals and family, and use as seed. He exceeded his acreage limit under a federal farm law and was fined, even though he never sold the extra wheat.

Procedural history

The farmer sued to block the penalty and challenge the law. A federal district court ruled for him. The government appealed directly to the Supreme Court.

Issue

Can Congress, using its power over interstate commerce, regulate and penalize wheat that a farmer grows and uses entirely on his own farm, with none of it sold or shipped anywhere?

Holding

Yes. Even wheat grown only for use on the farm can be regulated under the commerce power because, when many farmers do this, it has a large effect on the national supply and price of wheat.

Reasoning

One farmer's home grown wheat seems tiny, but added up across many farmers, it reduces how much wheat gets bought and sold nationally, significantly affecting price and supply, so Congress can regulate it.

Opinions

Majority (Jackson): Home grown wheat can be regulated because, combined with that of other farmers, it substantially affects interstate wheat prices and supply.

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Why was Roscoe Filburn penalized under the Agricultural Adjustment Act?

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