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Wickard v. Filburn
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Wickard v. Filburn : ウィキペディア英語版
Wickard v. Filburn

''Wickard v. Filburn'', 317 U.S. 111 (1942), was a United States Supreme Court decision that dramatically increased the power of the federal government to regulate the economy. Filburn was a test case. The goal of the business interests that financed the legal challenge all the way to the Supreme Court was to convince the Court to declare the entire federal crop support program unconstitutional and thereby end it. The Constitution gives the Congress the power to regulate commerce between the states. Congress decided that wheat was an important part of interstate commerce, and the growing of wheat therefore played a critical role. If farmers purchased wheat to feed their animals, that obviously was commerce. If farmers grew wheat only to their animals, that also affected interstate commerce. The Filburn decision supported what Congress had done, and said the Constitution enabled congressional regulation that included economic activity that was only indirectly related to interstate commerce. Filburn remains the law of the land despite objections that it stretched the original meaning of the Constitution.
An Ohio farmer, Roscoe Filburn, was growing wheat for use to feed animals on his own farm. The U.S. government had established limits on wheat production based on acreage owned by a farmer, in order to stabilize wheat prices and supplies. In 1941 Filburn grew more than the limits permitted and he was ordered to pay a penalty of $117.11. He claimed his wheat was not sold in interstate commerce and so the penalty could not apply to him.The Supreme Court stated "The intended disposition of the crop here involved has not been expressly stated..."and later "Whether the subject of the regulation in question was "production," "consumption," or "marketing" is, therefore, not material for purposes of deciding the question of federal power before us () ()ut even if appellee's activity be local and though it may not be regarded as commerce, it may still, whatever its nature, be reached by Congress if it exerts a substantial economic effect on interstate commerce and this irrespective of whether such effect is what might at some earlier time have been defined as 'direct' or 'indirect.'"〔Wickard, Sect. of Agriculture, et al. v. Filburn, 317 US 111(1945)at 125.

https://scholar.google.com/scholar_case?case=17396018701671434685&q=Wickard+v.+Filburn,+317+US+111&hl=en&as_sdt=8000006〕
The Supreme Court interpreted the United States Constitution's Commerce Clause under Article 1 Section 8, which permits the United States Congress "To regulate Commerce with foreign Nations, and among the several States, and with the Indian Tribes". The Court decided that Filburn's wheat growing activities reduced the amount of wheat he would buy for animal feed on the open market, which is traded nationally (interstate), and is therefore within the purview of the Commerce Clause. Although Filburn's relatively small amount of production of more wheat than he was allotted would not affect interstate commerce itself, the cumulative actions of thousands of other farmers just like Filburn would certainly become substantial. Therefore, according to the court, Filburn's production could be regulated by the federal government.
== Background ==
The Agricultural Adjustment Act of 1938 limited the area that farmers could devote to wheat production. The stated purpose of the act was to stabilize the price of wheat in the national market by controlling the amount of wheat produced. The motivation behind the Act was a belief by Congress that great international fluctuations in the supply and demand for wheat were leading to wide swings in the price of wheat, which were deemed to be harmful to the U.S. agricultural economy. The Supreme Court's decision states that the parties had stipulated as to the economic conditions leading to passage of the legislation:
Roscoe Filburn was a farmer in what is now suburban Dayton, Ohio who admitted producing wheat in excess of the amount permitted. He maintained, however, that the excess wheat was produced for his private consumption on his own farm. Since it never entered commerce at all, much less interstate commerce, he argued that it was not a proper subject of federal regulation under the Commerce Clause.
In July 1940, pursuant to the Agricultural Adjustment Act (AAA) of 1938, Filburn's 1941 allotment was established at and a normal yield of 20.1 bushels of wheat per acre. Filburn was given notice of the allotment in July 1940 before the Fall planting of his 1941 crop of wheat, and again in July 1941, before it was harvested. Despite these notices, Filburn planted and harvested 239 bushels from his of excess area.〔 〕
The Federal District Court ruled in favor of Filburn. The Act required an affirmative vote of farmers by plebiscite to implement the quota. Much of the District Court decision related to the way in which the Secretary of Agriculture had campaigned for passage: The District Court had held that the Secretary's comments were improper. The government then appealed to the Supreme Court of the United States, which called the District Court's holding against the campaign methods which led to passage of the quota by farmers a "manifest error." The court then went on to uphold the Act under the Interstate Commerce Clause.

抄文引用元・出典: フリー百科事典『 ウィキペディア(Wikipedia)
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