Wickard v. Filburn (1942)

Context

Economic Climate: Post-Great Depression era with a weak economic climate.
Legislation Enacted: New Deal legislation aimed to stabilize the economy.
- Agricultural Adjustment Act of 1938: Imposed quotas on wheat production due to a nationwide surplus.

Farmer: Filburn, operating a small dairy farm in Ohio.
Issue: Filburn grew more wheat than his quota allowed, primarily for home consumption and livestock feed.
Legal Action: Filburn fined; he sued Wickard, Secretary of Agriculture.
- Argument: Filburn claimed his wheat production wasn't subject to Congress's Commerce Clause authority as it didn't enter interstate commerce.

Initial Ruling: District court sided with Filburn, declaring the act unconstitutional as applied to him.
Supreme Court Question: Can Congress regulate in-state activities under the Commerce Clause if they affect interstate commerce?

Ruling: Congress can regulate in-state activities if they have a substantial effect on interstate commerce.
- Reasoning by Justice Jackson:
  - Wheat for home consumption can affect interstate commerce.
  - Aggregation Doctrine: Examines the collective impact of individual activities on interstate commerce.
    - Considered the effect of all wheat grown for home consumption.
    - Filburn's wheat, though not sold, affected market demand.
Outcome: Quota forced Filburn to buy wheat from the national market, increasing demand – aligning with the statute's purpose.

Landmark Decision: Established that Congress's Commerce Clause authority extends to in-state activities through the aggregation doctrine.
Criticism and Influence:
- Criticized for broad interpretation of the Commerce Clause.
- Continues to influence modern Supreme Court decisions.