Under
the Agricultural Adjustment Act, the Secretary of Agriculture set a quota
for wheat production.Under
the quota, each grower was given an allotment.
Filburn
lived in Ohio and grew wheat and dairy.He grew more than his allotment and was fined.He proceeded to sue the Secretary
of Agriculture.
Trial
Court found for Filburn and issued an injunction against collection of the
fine.The injunction was
appealed to the US Supreme Court.
US
Supreme Court reversed the injunction.
The
Court noted that this Act extends federal regulation to production
intended for consumption on the farm (Filburn fed the wheat to his cows).
However,
Filburn's wheat competed with wheat sold in interstate commerce. The
Court reasoned that if Filburn had not used home-grown wheat, he would
have had to buy wheat on the open market. The Court held that Congress's
power to regulate commerce was not limited to the supply side of
commerce, but that it could regulate demand as well. The Court also held that Congress
could regulate wholly intrastate, non-commercial activity if such
activity, viewed in the aggregate, would have a substantial effect on
interstate commerce, even if the individual effects are trivial.
From
the conservative point of view, this case represents the pinnacle of
Congressional intervention into State affairs.