Congress passed the Agricultural
Adjustment Act, which gave the
Secretary of Agriculture the power to set a quota for wheat production.
Under the quota, each wheat
grower was given an allotment of wheat they could grow per year.
Congress felt that the Interstate
Commerce Clause gave them the
authority to set quotas.
Filburn lived in Ohio and grew
wheat and dairy. He grew more than his allotment and was fined. He sued
the Secretary of Agriculture.
Filburn argued that Congress
did not have the power to limit how much wheat he was growing because the
Interstate Commerce Clause didn't
apply.
Filburn didn't sell his
wheat across State lines.
The Trial Court found for
Filburn and issued an injunction against collection of the fine. The US
appealed.
US Supreme Court reversed.
The US Supreme Court noted
that the Agricultural Adjustment Act
extended Federal regulation to production intended for consumption on the
farm (Filburn fed the wheat to his cows).
However, the Court found
that Filburn's wheat competed with wheat sold in interstate commerce.
Therefore it was covered by the Interstate Commerce Clause.
The Court reasoned that if
Filburn had not used home-grown wheat, he would have had to buy wheat on
the open market.
Basically, this case said that
Congress's power to regulate commerce was not limited to the supply side
of commerce, but that it could regulate demand as well.
That means that Congress can
use the Interstate Commerce Clause
to regulate wholly intrastate, non-commercial activity if such activity,
viewed in the aggregate, would have a substantial effect on interstate
commerce, even if the individual effects are trivial.
From the conservative point of
view, this case represents the pinnacle of Congressional intervention into
State affairs.
