Wickard v. Filburn

In Wickard v. Filburn, 317 U.S. 111 (1942) an Ohio farmer raised wheat on 23 acres of land. He consumed most of the wheat on his farm, either by feeding it to livestock, making flour for personal use, or using it to produce seeds for future crops. The Secretary of Agriculture assessed a penalty against the farmer for exceeding by 12 acres his allotment under a federal statute regulating wheat production. The Supreme Court upheld the assessment, holding that the Congress's limitation of the farmer's wheat production was a valid exercise of its authority under the Commerce Clause to regulate interstate commerce. The United States Supreme Court stated that one of the primary purposes of the Act in question was to increase the market price of wheat and to limit the volume of wheat that could affect the market. Therefore, the Court concluded, one individual's home-consumption of wheat would have a substantial influence on price and market conditions when that individual activity was "taken together with that of many others similarly situated." 317 U.S. at 128. The farmer owned and operated a small farm for many years, maintaining a herd of dairy cattle, selling milk, raising poultry, and selling poultry and eggs. It had been the farmer's practice to raise a small acreage of winter wheat. He would then sell a portion of the crop; use a portion to feed poultry and livestock on the farm, some of which were sold; to use some in making flour for home consumption; and to keep the rest for the following seeding. The federal government established quotas on the amount of wheat which he could grow on his farm, but he argued that these quotas were unenforceable against him since the production of wheat for his own use was local in nature and did not directly affect interstate commerce. The United States Supreme Court disagreed. "Even if appellee's activity be local and though it may not be regarded as commerce, it may still, whatever its nature, be reached by Congress if it exerts a substantial economic effect on interstate commerce and this irrespective of whether such effect is what might at some earlier time have been defined as 'direct' or 'indirect.'" Id. at 125. The effect of the farmer's home use of the home-produced wheat on interstate commerce "may be trivial by itself but is not enough to remove him from the scope of federal regulation where, as here, his contribution, taken together with that of many others similarly situated, is far from trivial." Id. at 127-128.