Wickard v. Filburn

The Agricultural Adjustment Act of 1938 (the act) sought to stabilize national wheat prices by controlling the amount of wheat in interstate commerce, preventing surpluses and shortages. The act required Secretary of Agriculture Claude Wickard (defendant) to annually establish an acreage allotment for the upcoming wheat crop. That allotment was apportioned among the states, then among each state’s regions, and finally among individual farms. Roscoe Filburn (plaintiff) operated a small farm in Ohio. He primarily raised dairy cattle and poultry, selling milk, eggs, and chicken. He also grew a small wheat crop. He would sell a portion of the crop and use the rest to feed his livestock and make flour for personal use. Filburn’s assigned wheat allotment for 1941 was 11.1 acres, but he sowed wheat on 23 acres. Under the act, he was subject to a $117.11 penalty for the excess wheat production. Filburn sued Wickard, arguing that the act was unconstitutional because Congress’s Commerce Clause authority did not allow it to regulate the production of wheat grown for noncommercial purposes such as on-farm use. Filburn argued that such production and consumption were wholly local in nature, meaning that they did not directly relate to interstate commerce and were not subject to regulation under the Commerce Clause. The district court agreed with Filburn, deeming the act unconstitutional as applied to wheat production for localized use. Wickard appealed to the United States Supreme Court.