United States v. Butler
United States v. Butler (1936) involved a challenge to the Agricultural Adjustment Act of 1933, a major New Deal program that attempted to stabilize the agricultural sector of the economy by providing for farm subsidies. Funds for the subsidies were generated by an excise tax on the primary processors of the products involved.
After articulating a broad view of the scope of the federal government’s constitutional authority to tax and spend, Justice Owen Roberts nevertheless concluded that the act is a plan “to regulate and control agricultural production, a matter beyond the powers delegated to the federal government.” “They are,” according to Roberts, “but means to an unconstitutional end.” For Roberts and his colleagues on the Court, the tax and spending program was merely a guise for a regulation of agriculture, a field reserved to the states by the Tenth Amendment to the Constitution.
Last Updated: 2006