Wickard Vs Filburn Case Study
Wickard v. Filburn
312 U.S. 100 (1941)
Facts
The Agricultural Adjustment Act passed by Congress in 1938 allowed the secretary of agriculture to establish production limits on grains to stop wild swings in grain prices by eliminating surpluses and shortfalls. In 1940 the secretary of agriculture set the production limits for 1941. Roscoe Filburn, an Ohio farmer, planted not only his allotted amount but some other to produce wheat for home consumption. Roscoe was fined $117.11 for the excess planting. Roscoe refused to pay the fine, claiming that Congress exceeded its powers under the Commerce Clause by regulating the planting by an individual of wheat on his own property for on-farm consumption. The lower courts ruled in favor of Filburn and Secretary Wickard appealed. Wickard argued that the quota on planting is a valid exercise of Congress’ commerce regulatory power and the quota system allows for efficient enforcement of the …show more content…
Holding
No, 9-0 in favor of Wickard. Justice Jackson wrote the unanimous opinion.
Reasoning
1. If Congress can fix prices, then it has the ability to regulate planting and production. The power to regulate commerce is emphatic and all-embracing as held in Gibbons v. Odgen and can only be restrained through political rather than judicial means.
2. The Commerce Clause allows Congress the authority to regulate the price of wheat to the extent that farmers could produce wheat to meet their own home needs, the demand for wheat is affected. While Filburn’s production alone may have a minimal effect on commerce, the combination of these minimal productions would have a substantial effect on commerce. Although Filburn’s planting is local it can still be regulated by Congress as it has the potential to have a substantial economic effect on commerce, regardless whether that affect is direct or indirect.
3. The lower court decision is reversed.
Concurrences/Dissents
N/A
312 U.S. 100 (1941)
Facts
The Agricultural Adjustment Act passed by Congress in 1938 allowed the secretary of agriculture to establish production limits on grains to stop wild swings in grain prices by eliminating surpluses and shortfalls. In 1940 the secretary of agriculture set the production limits for 1941. Roscoe Filburn, an Ohio farmer, planted not only his allotted amount but some other to produce wheat for home consumption. Roscoe was fined $117.11 for the excess planting. Roscoe refused to pay the fine, claiming that Congress exceeded its powers under the Commerce Clause by regulating the planting by an individual of wheat on his own property for on-farm consumption. The lower courts ruled in favor of Filburn and Secretary Wickard appealed. Wickard argued that the quota on planting is a valid exercise of Congress’ commerce regulatory power and the quota system allows for efficient enforcement of the …show more content…
Holding
No, 9-0 in favor of Wickard. Justice Jackson wrote the unanimous opinion.
Reasoning
1. If Congress can fix prices, then it has the ability to regulate planting and production. The power to regulate commerce is emphatic and all-embracing as held in Gibbons v. Odgen and can only be restrained through political rather than judicial means.
2. The Commerce Clause allows Congress the authority to regulate the price of wheat to the extent that farmers could produce wheat to meet their own home needs, the demand for wheat is affected. While Filburn’s production alone may have a minimal effect on commerce, the combination of these minimal productions would have a substantial effect on commerce. Although Filburn’s planting is local it can still be regulated by Congress as it has the potential to have a substantial economic effect on commerce, regardless whether that affect is direct or indirect.
3. The lower court decision is reversed.
Concurrences/Dissents
N/A