United States v Butler (1936)

Congress implemented a processing tax on agricultural commodities. This was known as the 1933 Agricultural Adjustment Act. Under this act, farmers who reduced their acreage as promised were to receive funds for the government for their compliance. Farmers who refused would have funds withheld. Congress’s intent was to promote the general welfare of farmers as a problem of an agricultural commodities crisis arose, causing farmers to go under.

In a 6- 3 decision, the court held that the 1933 Agricultural Adjustment Act was an unconstitutional exercise of power. Justice Roberts read the majority opinion, which, ruling in favor of the respondent William Baker, held that Congress exceeded its constitutional taxing and spending powers with the act. The court ruled that, the act was unconstitutional because congress was regulating and controlling agricultural production which was not part of their powers in the constitution. Thus, the controlling of agriculture was not a federal issue, but a state issue.

“Even though Congress does have the power to tax and appropriate funds, argued Justice Roberts, in this case those activities were “but means to an unconstitutional end,” and violated the Tenth Amendment.” (Oyez) This power in the act was not a power delegated to the federal government under the spending clause.

Chief Justice Rehnquist, in his majority opinion, cited the case United States v Butler (1936) as setting the precedent that “objectives not thought to be within Article I’s ‘enumerated legislative fields’ may nevertheless be attained through the use of the spending power and the conditional grant of federal funds” (south Dakota v Dole, 1987.p.2.)”. (High Stakes Accountability)


“United States v. Butler.” Oyez. Chicago-Kent College of Law at Illinois Tech, n.d. Dec 6, 2015. https://www.oyez.org/cases/1900-1940/297us1

“United States v Butler.” Case briefs. N.p., n.d. Web. 06 Dec. 2015.

Rice, Jennifer King, and Christopher Roellike. “Federal Educational Control in No Child Left Behind.” High Stakes Accountability: Implications for Resources and Capacity. Charlotte: Information Age, 2009. 231-32. Print.

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