United States v. Butler

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Brief Fact Summary.

Congress used its taxing and spending powers to regulate local agricultural production. The regulation was challenged as being outside the scope of Congress’s powers.

Synopsis of Rule of Law.

Congress does not have an independent power to provide for the general welfare, separate from its power to tax and spend.

Facts.

The Agricultural Adjustment Act of 1933 (the Act), promulgated during the New Deal, was enacted by Congress to raise farm prices by cutting agricultural production. Under the Act, the Secretary of Agriculture could contract with farmers to limit the number of crops produced in return for benefit payments. The payments would come from a fund generated by taxes imposed on those farmers who exceeded their production limits. The tax was challenged as an unconstitutional control on agricultural production

Issue.

May Congress use its taxing and spending power to regulate in areas that are traditionally the concern of the states?

Held.

No. Judgment affirmed.
Congress many not regulate in certain areas solely to provide for the general welfare. Congress may only tax and spend for the general welfare.
Congress does not have the power to regulate in an area of local control. Agriculture is an area of local control. Since Congress does not have this direct power, they also cannot indirectly regulate by imposing a regulatory scheme.
The regulations are coercive in nature. If a farmer chose not to accept the government’s offer, he would be placed at a substantial disadvantage compared to those farmers who accepted the program. So, the program is not really voluntary, but coercive.
It is impermissible to make farmers contractually bind themselves to obey the Congressional regulations. Otherwise, there would be no limits on legislative power.

Dissent.

Congress undoubtedly has the power to tax the processing of agricultural products. Congress also has the power to use public funds to aid farmers, especially since the country is in the midst of a depression. Furthermore, Congress can limit those payments to only the farmers that reduce their crop production. Thus, there is no basis to make the Act unconstitutional because farmers have to promise to reduce their production.

Discussion.

Congress cannot use its taxing and spending power to regulate in areas that are traditionally controlled by the states.