In an attempt to reduce surpluses and stabilize agricultural prices in the years following the Great Depression, Congress passed a piece of New Deal era legislation called the Agricultural Adjustment Act of 1938. The act placed a maximum cap on the amount of wheat any farmer could produce.
Roscoe Filburn owned a dairy farm, where he grew wheat to feed his livestock and his family. The U.S. Department of Agriculture fined Filburn for going over his wheat quota. Filburn sued Secretary of Agriculture Claude R. Wickard to enjoin enforcement of the act.
Filburn argued that Congress had overstepped its commerce power by regulating the amount of wheat he produced, because Filburn was never going to sell his wheat (and thus place it in the stream of interstate commerce).
The United States Supreme Court had to decide whether Congress could regulate purely in-state activities like the private cultivation of wheat for personal consumption under its Commerce Clause authority. Ultimately, the Court held that Congress did have authority to regulate purely in-state activities if those activities had substantial effects on interstate commerce.
Because growing wheat for personal use could, in the aggregate, have a substantial effect on interstate commerce, Congress was free to regulate it.
Though the decision was controversial, Wickard v. Filburn, 317 US. 111 (1942), remains good law.
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