Wickard v. Filburn

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Wickard v. Filburn was a major judicial case in the United States Supreme Court, which affected the interpretation of certain laws - namely the agricultural clauses of the New Deal , as well as the so-called Commerce Clause of the US Constitution. The case was tried in May and October 1942 and finally decided on November 9, 1942.

In order to stabilize prices, the federal government had restricted wheat production according to the acreage of each farmer. However, an Ohio farmer, Roscue Filburn, grew more wheat than the regulations required. However, he fed the wheat to his own cattle without the wheat being sold or even changing hands. However, since only the trade between states, those with foreign countries and that with the Indian peoples falls under the competence of the US government, he claimed that the penalty for his overproduction was illegally imposed.

The Supreme Court then interpreted Section 8 of Article 1 of the Constitution , which the American Congress allows

to regulate Commerce with foreign Nations, and among the several States, and with the Indian Tribes.
(To regulate trade with foreign nations, and between the various states, and with the Indian tribes.)

The court found that growing his wheat reduced the amount of wheat Filburn should have bought on the open market, and since the price of wheat is usually determined by the national market situation, that law could also apply to the wheat that never finds commercial use. The court also took into account the cumulative impact of home growing by thousands of farmers.

background

The Agricultural Adjustment Act of 1938 was a law that regulated and restricted wheat production. Since the Congress considered the price fluctuations in the world market too dangerous for the domestic agriculture, it passed a law, which regulated the national supply.

In the judgment, the court mentioned:

  • During the 1930s, less than ten percent of wheat production was destined for export; in the 1920s, an average of more than a quarter of the wheat was exported. The oversupply meant that grain silos refused to accept the wheat, and the railways immediately refused to transport wheat - otherwise the wheat would be stored in freight wagons.
  • Numerous wheat exporting countries, including Argentina, Australia, Canada and the United States itself, tried programs to support wheat prices. In 1941, farmers who partnered with the Agricultural Adjustment Program received an average price of $ 1.16 per bushel , while the world market price was $ 0.40.

Roscoe Filburn was a farmer in what is now a suburban area of Dayton, Ohio . He admitted to producing more wheat than required by the program, but argued that the wheat was for personal consumption and ultimately not intended for international trade and thus did not affect the competence of the national legislature. According to the official assessment, Filburn was allowed to grow 4.5 hectares (11.1 acres ) of wheat and harvest 1.4 tons / hectare of wheat. However, he sown 9.3 hectares of wheat and harvested 6.5 tons too much.

Previous instance

The Federal District Court initially ruled in Filburn's favor and relied mainly on statements by the Agriculture Minister, who campaigned for the passage of the Agricultural Adjustment Act . According to this, the producers would have the right to set binding production quotas themselves, but this never happened.

The decision of the Supreme Court

The federal government moved the case to the Supreme Court, which called the previous Instant's judgment a manifest error . The case also occurred after the attack on Pearl Harbor (December 7, 1941), an event that united the American people behind the President. It also played a role in the fact that President Franklin D. Roosevelt was able to appoint eight of the nine judges at the time.

As described above, the Supreme Court followed the line of argument of the Ministry of Economic Affairs - namely that goods manufactured for personal use influence the price of goods traded, as these goods do not have to be bought on the free market. Therefore, if there is a legal basis for the regulation of traded goods, the federal government can also regulate the cultivation of non-commercial goods.

consequences

With Wickard v. Filburn began an era in which the Supreme Court in no way curtailed the power of Congress over Commerce Clause matters . This changed with the case of United States v. Lopez , who was ruled in 1995. In that case, the Supreme Court ruled that carrying a handgun near a school was not a commercial matter that came under the legislative competence of Congress. (Lopez, a student, was carrying an unloaded revolver; for a compensation of $ 44 he was assigned to deliver the weapon to someone else.) United States v. Lopez was, however, very tightly decided with 5: 4 votes, and the minority opinion stated that firearms violence by individual perpetrators does have a (cumulative) influence on the economy, according to which Congress is entitled to legislate here.