63 S.Ct. 1 (1942), 63 S.Ct. 2 (1942), 317 U.S. 1 (1942)
Tags: Constitutional Law, War Powers
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The case of Wickard v. Filburn involves a complaint filed by the appellee against the Secretary of Agriculture and other agricultural committee members. The appellee sought to prevent the enforcement of a marketing penalty imposed on his wheat crop and a declaratory judgment that the wheat marketing quota provisions of the Agricultural Adjustment Act were unconstitutional. The Agricultural Adjustment Act of 1938 regulates the amount of wheat that can be traded across states and countries to prevent irregular prices and trade barriers. The Secretary of Agriculture sets a national limit for the upcoming wheat crop based on specific guidelines, which is then divided among states, counties, and individual farms. In select situations, wheat farmers may be eligible for loans and payments. The lower court held that the Secretary's speech invalidated the referendum and that the amendment increasing the penalty for marketing excess was retroactive and violated the Fifth Amendment. The court permanently enjoined the appellants from collecting a penalty of more than 15 cents per bushel on the appellee's 1941 wheat crop and from subjecting the entire crop to a lien for payment of the penalty. However, the Secretary and co-defendants have appealed the decision.
The lower court was wrong about the Secretary's speech invalidating the referendum. Congress has broad power to regulate interstate and intrastate commerce, including activities that have a significant economic impact on interstate commerce. The regulation of home-grown wheat is necessary to stimulate commerce and achieve the Act's purpose. The Act is challenged as a deprivation of property without due process of law, but an Act of Congress cannot be deemed arbitrary and capricious and forbidden by the Due Process Clause just because it may work an inequitable result in a particular case.
The Agricultural Adjustment Act allows the government to regulate supply, and farmers cannot sell their crops as they wish without penalty. The lower court did not err in subjecting the entire crop to a lien for the payment of the penalty. The appellee has not shown that he is worse off due to the legislation, and denying him benefits without complying with the law does not violate due process. The decision of the lower court is reversed.
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