Brief Fact Summary.
Filburn, the respondent, was a dairy farmer in Ohio and sued Wickard, the Secretary of Agriculture, to enjoin enforcement of a marketing penalty imposed upon him under the Agricultural Adjustment Act.
Synopsis of Rule of Law.
Congress may regulate a local activity if it substantially affects economy on interstate commerce.
Its authority, extending to these interstate carriers as instruments of interstate commerce, necessarily embraces the right to control their operations in all matters having such a close and substantial relation to interstate traffic that the control is essential or appropriate to the security of that traffic, to the efficiency of the interstate service, and to the maintenance of conditions under which interstate commerce may be conducted upon fair terms and without molestation or hindrance.View Full Point of Law
Filburn was a farmer and raised a small acreage of wheat for consumption and sale. In 1941, He harvested wheat in excess of the quota designated under the Agricultural Adjustment Act of 1938. Thus, he had to pay a penalty for the excess grown. Filburn challenged the quota provisions of the Act as beyond the constitutional commerce power.
Is the Agricultural Adjustment Act of 1938 that require farmers not to exceed certain amount of quota for wheat and force them to pay penalty if there is excess valid under the Constitution?
Yes, Congress has the power to enact and execute the Act that demands wheat farmers not to exceed the quota, because even if the respondent’s activity is local and may not be considered as commerce, Congress may still regulate such activity if it exerts a substantial economic effect on interstate commerce. Congress does have such authority regardless of whether such effect is direct or indirect to interstate commerce.
Congress enacted the Act to increase the market price of wheat and limit its volume that could affect the market. Volume of agricultural products are one of the main factors that could substantially influence price and market conditions. If, however, the products are never marketed and only used for the farmers’ consumption, that will also affect the market because the farmer, by consuming the wheat he had grown himself, will not buy wheat in the market. The stimulation of commerce is certainly a use of the regulatory function by Congress. Thus, Congress rightfully concluded that home grown wheat could in any way have substantial effect in defeating its purpose to stimulate trade at increased prices.