Background: Roscoe Filburn owned a local farm outside of Dayton, Ohio on which he grew wheat. In the fall of 1940, he planted 23 acres of wheat for use within his own home. Under the Agricultural Adjustment Act of 1938 Roscoe was only permitted to plant 11 acres of wheat. This Act was instituted to limit the supply of wheat put into the market of interstate commerce. In July of 1941, due to the extra planting, Roscoe was fined $117. He refused to pay and filed suit asking the district court to find that the penalty violated his constitutional right to due process under law and exceeded the scope of Congress’ commerce clause power.
Supreme Court: Jackson wrote the unanimous opinion for the Court, which expanded the power of Congress to regulate economic activity, even to local activities like growing wheat for personal use. Jackson reasoned that even though the wheat itself did not enter the interstate commerce market Congress had the ability to regulate commodity prices and practices. Filburn was indirectly affecting the national market by growing wheat for personal use that he otherwise would have purchased on the open market, as well such personal growths could easily enter the interstate market thereby affecting the market price directly.
Legacy: The case is important because of how far it expanded Congress’ power to regulate economic activity. No longer was Congress limited to regulating what directly affected interstate commerce instead, they could broadly monitor acts that had a substantial effect on the market, even if it was only indirectly. The decision of this case has also played an important role in the recently decided case regarding the national healthcare act.