Wickard v. Filburn

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When reviewing New Deal Commerce Clause cases, Wickard v. Filburn (1942) begins by giving Congress unlimited power.

The facts of Wickard v. Filburn are straight forward. Roscoe Filburn, the Appelle, was a wheat farmer who farmed in Ohio. He sold wheat, which was over the limiting of the Agricultural Adjustment Act of 1938. He was penalized by the government and sued.

Here’s the decision of Wickard v. Filburn. The case was unanimous. The majority was all Supreme Court Justices: Owen J. Roberts, Hugo Black, Stanley F. Reed, Felix Frankfurter, William O. Douglas, Frank Murphy, Robert H. Jackson, James F. Byrnes, and Chief Justice Harlan F. Stone. There was no dissenting Justices.

Here’s the holding of Wickard v. Filburn, which dealt with Congress’ Commerce Clause power. The decision states: Production quotas under the Agricultural Adjustment Act of 1938 were constitutionally applied to agricultural production that was consumed purely intrastate, because its effect upon interstate commerce placed it within the power of Congress to regulate under the Commerce Clause. Southern District of Ohio reversed.” Essentially, Congress could now regulate any economic activity.

The Wickard v. Filburn case is famous for the Commerce Clause of the constitution. Basically, the case said Congress can regulate wheat since it’s economic activity and effects interstate commerce. Also, farming wheat effects interstate and intrastate economic activity; therefore, Congress can regulate it under the Commerce Clause. Finally, the case introduced the substantial effects test to determine economic activity in later Commerce Clause cases.

From 1942 to the 1970’s, Congress had unlimited power under the commerce clause. Congress could regulate anything under the sun. The only limit of Congress’s commerce power was their imagination. Indeed, all law students were taught during this time that Congress had no end to their power under the commerce power.

In Wickard, the Supreme Court went the farthest with it’s interpretation of the commerce power. With the commerce clause, Congress regulated labor conditions, minimum wage, wage hours, union collective bargaining, the fixed number of business employees, etc. Consequently, the Supreme Court wouldn’t narrow it’s interpretation of Commerce power until the 1980’s with the Rehnquist Revolution.

Wickard was a New Deal case in the time of President Franklin Delano Roosevelt. New Deal cases gave Congress power to regulate labor conditions of the state. Prior, states regulated their own labor conditions. Furthermore, this case took away state police power to regulate local labor conditions. Often, New deal cases flew in the face of federalism and state sovereignty.

In the final analysis, Wickard v. Filburn and the government’s misguided Agricultural Adjustment Act didn’t help the great depression. Wickard couldn’t grow extra wheat to feed his chickens. Plus, the government policy didn’t stop the depression by putting more money in farmer’s pockets. In fact, the government economic policy extended the great depression in a time when people should of been growing more wheat.

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