Filburn (D) owned an operated a farm where he grew some wheat. He sold some of the wheat but used the other wheat for his own purposes (feeding chickens, household use).
The Agricultural Adjustment Act of 1938 set maximum acreages and bushel limits to wheat production. D exceeded his allotment given by the AAA.
D argued that the AAA was attempting to regulate his personal use of wheat not that wheat which he sold in commerce and should be unconstitutional.
Procedural History:
Lower court held AAA unconstitutional.
SCOTUS reversed, AAA constitutional.
Issues:
May Congress, in regulating interstate commerce, also regulate activities which are purely local in nature?
Holding/Rule:
Congress may, in regulating interstate commerce, also regulate activities which are purely local in nature if the total, nationwide effect of the local activities would have an effect on interstate commerce.
Reasoning:
This case would be easy if it did not deal with the personal consumption of wheat since US v. Darby sets out that Congress has the power to regulate production of goods in commerce.
The distinction between direct and indirect effects on interstate commerce is abandoned.
Congress may regulate purely local activities if such activities exert a substantial economic effect on interstate commerce.
That D's own contribution to the demand for wheat may be trivial by itself is not enough to remove him from the scope of federal regulation where his contribution, taken together with that of many others similarly situated, is far from trivial.
The wheat here supplies a need of the may who grew it which would otherwise be reflected by purchases in the open market.
