Can Congress constitutionally regulate a farmer's production of wheat intended solely for personal use under the Commerce Clause, without violating the Fifth Amendment's Due Process protections?

Roscoe Filburn, an Ohio farmer, cultivated wheat for personal use on his farm. The Agricultural Adjustment Act of 1938, amended in 1941, imposed restrictions on wheat production, including wheat grown for on-farm consumption. Filburn exceeded his allotted acreage by 11.9 acres, resulting in an excess production of 239 bushels. This violation incurred a penalty of 49 cents per bushel, totaling $117.11.

Filburn refused to pay the penalty or comply with the regulations. He challenged the Act's constitutionality, arguing that it exceeded Congress's authority under the Commerce Clause and violated the Due Process Clause of the Fifth Amendment. This dispute led to legal proceedings, with Filburn contesting the federal government's right to regulate wheat grown for personal use on his farm.

Filburn initiated legal proceedings by filing a complaint in the U.S. District Court for the Southern District of Ohio. He named the Secretary of Agriculture and members of the County Agricultural Conservation Committee as defendants. Filburn sought an injunction to prevent enforcement of the marketing penalty and a declaratory judgment that the wheat marketing quota provisions were unconstitutional.

The District Court ruled in Filburn's favor. It held that the Secretary's pre-referendum speech invalidated the referendum and that the amendment increasing penalties was unconstitutionally retroactive.

Following the District Court's decision, the case was appealed directly to the Supreme Court.

(Jackson, J.)

Yes. Congress can constitutionally regulate a farmer's production of wheat intended solely for personal use under the Commerce Clause without violating the Fifth Amendment's Due Process protections. The Commerce Clause extends to activities that, taken in aggregate, substantially affect interstate commerce, even if those activities are local and not commercial in nature. Home-grown wheat, though intended for personal consumption, competes with wheat in commerce and influences price and market conditions when considered collectively. This economic impact brings such activity within Congress's regulatory purview. The substantial effects test applies regardless of whether the regulated activity is characterized as "direct" or "indirect" in its influence on interstate commerce. Previous distinctions between direct and indirect effects are no longer controlling. The Agricultural Adjustment Act's regulation of wheat production serves a legitimate governmental interest in stabilizing wheat prices and does not arbitrarily deprive farmers of property. The Act's provisions are rationally related to Congress's goal of regulating the national wheat market and do not violate due process principles. The Fifth Amendment does not prohibit reasonable regulation of economic activities that substantially affect interstate commerce, even when those activities occur entirely within a single state. The interconnected nature of the national wheat market justifies federal oversight of local production to effectively implement Congress's broader regulatory scheme.