In Gonzales v. Raich, 545 U.S. 1 (2005), the United States Supreme Court held that the Commerce Clause authority granted to Congress included the power to enact the Controlled Substances Act of 1970 (21 USC 801 et seq.), which criminalized the manufacture, distribution or possession of marijuana by intrastate growers, and prohibited the local cultivation and use of marijuana for medical purposes by individuals pursuant to the State of California's Compassionate Use Act of 1996 (Cal Health & Safety Code 11362.5). The facts of Gonzales are highly distinguishable because it dealt with a controlled substance, marijuana, for which there was a national market in both supply and demand. The Gonzales case was also based squarely on the precedent of Wickard v. Filburn (317 US 111, 63 S Ct 82, 87 L Ed 122 1942), which held that the Commerce Clause granted to Congress the power to regulate the production of wheat intended wholly for the farmer's own consumption, and thus regulate a purely "intrastate" activity that is not itself "commercial," because failure to regulate this activity would undercut the regulation of the interstate market for that commodity (id. at 124-133). The Court in Gonzales held that there was a rational basis for Congress to conclude that leaving home-consumed marijuana outside federal control would affect price and market conditions, and undercut the comprehensive regulatory scheme of controlling the supply and demand of controlled substances (Gonzales v. Raich).