Wickard v. Filburn
Citation and Court
317 U.S. 111 (1942). United States Supreme Court. Justice Jackson, writing for a unanimous Court.
Facts
Roscoe Filburn was an Ohio farmer who grew wheat in excess of the federal quota set by the Agricultural Adjustment Act of 1938. The excess wheat was not sold but was consumed on his own farm — fed to livestock and used for personal consumption. The USDA penalized him for the overproduction. Filburn argued that wheat grown and consumed entirely on his own property was beyond the reach of Congress’s commerce power because it was purely local and non-commercial activity.
Issue
Does the Commerce Clause give Congress power to regulate the production of wheat that is grown and consumed entirely on a private farm and never enters the stream of interstate commerce?
Holding
Yes. Congress may regulate Filburn’s home-grown wheat because, when viewed in the aggregate, the activity of many farmers growing wheat for home consumption substantially affects interstate commerce by suppressing demand for wheat on the open market.
Rule / Doctrine
The Aggregate Effects (Substantial Effects) Test: Congress may regulate purely local, even non-commercial, activities if those activities, taken in the aggregate across all similarly situated persons, substantially affect interstate commerce. Courts do not ask whether the individual actor’s conduct is trivial in isolation; they ask whether the class of activities has a substantial effect on commerce.
Significance
Wickard represents the high-water mark of Commerce Clause expansion before the Rehnquist Court’s limits in United States v. Lopez and United States v. Morrison. It validates the “aggregation principle,” meaning that no individual transaction is too small for federal regulation so long as the cumulative economic effect is significant. The case provided the constitutional foundation for broad New Deal economic regulation and was later relied upon in Gonzales v. Raich (2005) to uphold federal drug laws as applied to home-grown marijuana.