United States v. Butler

Brief Fact Summary.

Congress passed a law to regulate the production of crops during the Great Depression, and it was challenged as unconstitutional.

Synopsis of Rule of Law.

A Congressional Act regulating agriculture violates the Tenth Amendment and exceeds the taxing power.

Facts.

There was a crisis in the agricultural market during the Great Depression, making many farmers go under. Congress passed the Agricultural Adjustment Act to put some controls on the market, including taxing people who exceed production.

Issue.

Does the Agricultural Adjustment Act conflict with the Constitution?

Held.

It does not conflict with the taxing power, but it does conflict with the Tenth Amendment.

Discussion.

Art. 1, § 8, the spending power, vests sundry powers in Congress. Congress is expressly empowered to lay taxes to provide for the general welfare. The phrase “to provide for the general welfare” qualifies the power “to lay and collect taxes.”

The power of Congress to authorize expenditure of public moneys for public purposes is not limited by the direct grants of legislative power found in the Constitution.

The Act invades the rights of the states and violates the Tenth Amendment. There is no federal power to regulate agriculture.

Therefore, it has no power to enforce its commands by using the taxing and spending power to ensure compliance.