At the same time, the New Deal was being enacted in an attempt to create economic prosperity. President Franklin D. Roosevelt signed a number of laws including child labor laws, farming quotas, social security, and many other programs. Perhaps not surprisingly, these laws were immediately contested. Also not surprisingly, many of these laws were found to contradict precedent and thus struck down.
This was not the first case the Supreme Court heard from the New Deal programs, nor was it the first case where the Court upheld the program. Instead, this case is important because it defined “interstate commerce” very broadly. On its face, interstate commerce could be and had been defined as goods or services crossing state or international borders. This was a fairly easy to understand definition.
Farmer Filburn was accused of violating an agricultural program designed to stimulate the economy, a New Deal program. Under the traditional definition of interstate commerce, the Farmer was clearly unaffected by the law. Nothing he was selling was “interstate” as nothing crossed the border.
In upholding the violation, the Supreme Court created an aggregation test. Where any particular case may be “trivial,” all of those minor and little violations severely disrupted the federal program. Thus, the entire market is to be considered and if the market is interstate, then any individual actor is participating in interstate commerce.
This case has been used for numerous federal programs since its decision. These programs include everything from wage and hour laws to the Affordable Healthcare Act. Along with the other decisions upholding the New Deal programs, Wickard v. Filburn created a significant amount of authority in the Federal government. The effect was to shift some responsibilities over citizens away from the States and to the Federal Government.
While the facts and details of the case limit its scope, the expansion of Federal power is still an important factor in modern government decision making and authority.