United States v. Butler case brief

United States v. Butler case brief summary

297 U.S. 1 (1936)

CASE SYNOPSIS

Petitioner government claimed cotton taxes from respondent receivers under the Agricultural Adjustment Act (Act), 48 Stat. 31 (1933), and the receivers recommended that the claim be disallowed. The district court found the taxes valid and ordered them paid, but the United States Circuit Court of Appeals for the First Circuit reversed.

CASE FACTS
The government argued that the Act was valid because Congress was authorized to appropriate and authorize spending for the "general welfare" under U.S. Constitutional Article I, § 9, cl. 7, and that the Act was an effort to aid farmers during the great depression.

DISCUSSION

• While the Act might have been within Congress' power if it fell within the ambit of the term "general welfare," the Court did not have to reach the question of the interpretation of that whether it did so because the Act was unconstitutional on other grounds. 
• The Act was clearly designed to regulate agriculture by coercing a non-cooperating minority to a desired action with economic pressure. 
• However, the power to regulate agriculture was not granted to Congress by the Constitution, but rather, was reserved to the States. 
• The tax, the appropriation of the funds raised, and the direction for their disbursement, were possibly permissible means to an unconstitutional end. 
• Congress had no power to enforce its commands on the farmer to the ends sought by the Act, and it could not indirectly accomplish those ends by taxing and spending to purchase compliance.

CONCLUSION

The Court affirmed the judgment that the Act was an unconstitutional assertion of power by Congress and that the tax imposed on the receivers was invalid.