United States v. Butler
Supreme Court of the United States
Argued December 9 – December 10, 1935 Decided January 6, 1936
Full case name: United States v. Butler et al. Citations: 297 U.S. 1
Holding
The Agricultural Adjustment Act is an unconstitutional exercise of power.
Court membership
Chief Justice: Charles Evans Hughes Associate Justices: Willis Van Devanter, James Clark McReynolds, Louis Brandeis, George Sutherland, Pierce Butler, Harlan Fiske Stone, Owen Josephus Roberts, Benjamin N. Cardozo
Case opinions
Majority by: Roberts Joined by: Hughes, Van Devanter, McReynolds, Sutherland, Butler Dissent by: Stone Joined by: Brandeis, Cardozo
Laws applied
U.S. Const. amend. X, Agricultural Adjustment Act

United States v. Butler, 297 U.S. 1 (1936), was a case in which the Supreme Court of the United States ruled constitutional the processing taxes instituted under the 1933 Agricultural Adjustment Act. Justice Owen Josephus Roberts argued that the tax was "but a means to a constitutional end" that didn't violate the Tenth Amendment. Image File history File links Seal_of_the_United_States_Supreme_Court. ... Federal courts Supreme Court Chief Justice Associate Justices Elections Presidential elections Midterm elections Political Parties Democratic Republican Third parties Libertarian Party State & Local government Governors Legislatures (List) State Courts Counties, Cities, and Towns Other countries Politics Portal      The Supreme Court of the United States (SCOTUS) is the highest judicial body... Charles Evans Hughes (April 11, 1862 – August 27, 1948) was Governor of New York, United States Secretary of State, Associate Justice and Chief Justice of the United States. ... Willis Van Devanter (April 17, 1859 - February 8, 1941), associate justice of the United States Supreme Court, January 3, 1911 to June 2, 1937. ... Justice McReynolds, c. ... Louis Dembitz Brandeis (November 13, 1856 – October 5, 1941) was an American litigator, Supreme Court Justice, advocate of privacy, and developer of the Brandeis Brief. ... George Sutherland (March 25, 1862 – July 18, 1942) was an English-born U.S. jurist and political figure. ... Pierce Butler (March 17, 1866 – November 16, 1939) was an American jurist who served as an Associate Justice of the United States Supreme Court from 1923 until his death in 1939. ... Harlan Fiske Stone (October 11, 1872 – April 22, 1946) was an American lawyer and jurist who served as the dean of Columbia Law School, Attorney General of the United States, Associate Justice of the U.S. Supreme Court and later Chief Justice of the United States. ... Owen Josephus Roberts (May 2, 1875 – May 17, 1955) was an Associate Justice of the United States Supreme Court for fifteen years. ... Benjamin Nathan Cardozo (May 24, 1870–July 9, 1938) is considered one of the greatest American jurists, and is remembered not only for his landmark decisions on negligence but also his modesty, philosophy and writing style, which is considered remarkable for its prose and vividness. ... Amendment X (the Tenth Amendment) of the United States Constitution, which is part of the Bill of Rights, was ratified on December 15, 1791. ... The Agricultural Adjustment Act (or AAA) (Public law 73-10 of May 12, 1933) restricted production during the New Deal by paying farmers to reduce crop area. ... Federal courts Supreme Court Chief Justice Associate Justices Elections Presidential elections Midterm elections Political Parties Democratic Republican Third parties Libertarian Party State & Local government Governors Legislatures (List) State Courts Counties, Cities, and Towns Other countries Politics Portal      The Supreme Court of the United States (SCOTUS) is the highest judicial body... Year 1933 (MCMXXXIII) was a common year starting on Sunday. ... The Agricultural Adjustment Act (or AAA) (Public law 73-10 of May 12, 1933) restricted production during the New Deal by paying farmers to reduce crop area. ... Owen Josephus Roberts (May 2, 1875 – May 17, 1955) was an Associate Justice of the United States Supreme Court for fifteen years. ... Amendment X (the Tenth Amendment) of the United States Constitution, which is part of the Bill of Rights, was ratified on December 15, 1791. ...

A tax for an impermissible regulatory purpose

The main point of the case was whether certain provisions of the Agricultural Adjustment Act of 1933 conflicted with the Constitution. In the Act, a tax was imposed on processors of farm products, the proceeds to be paid to farmers who would reduce their area and crops. The intent of the act was to increase the prices of certain farm products by decreasing the quantities produced.

The Court held that the so-called tax was not a true tax, because the payments to farmers were coupled with unlawful and oppressive coercive contracts and the proceeds were earmarked for the benefit of farmers complying with the prescribed conditions. Making the payment of a government subsidy to a farmer conditional on the reduction of his planned crops went beyond the powers of the national government. Specifically, the Court said:

“The act invades the reserved rights of the states. It is a statutory plan to regulate and control agricultural production, a matter beyond the powers delegated to the federal government. The tax, the appropriation of the funds raised, and the direction for their disbursement, are but parts of the plan. They are but means to an unconstitutional end.”

Taxation for the general welfare

Although it struck down the Act, the Court dealt positively with expenditure of funds to advance the general welfare as specified in Article 1 § 8 of the Constitution. The Court stated that the issue “presents the great and the controlling question in the case.” After comparing expansive vs. restrictive interpretations of the Spending Clause, the Court adopted the philosophy that:

“The clause confers a power separate and distinct from those later enumerated [,] is not restricted in meaning by the grant of them, and Congress consequently has a substantive power to tax and to appropriate, limited only by the requirement that it shall be exercised to provide for the general welfare of the United States. … It results that the power of Congress to authorize expenditure of public moneys for public purposes is not limited by the direct grants of legislative power found in the Constitution.”

The idea that Congress has authority separate and distinct from powers granted by enumeration was (and still is) controversial.^{[citation needed]} The fact that the Court struck down the Act despite an expansive interpretation of the Spending Clause reflects the turmoil in the Court’s thinking at this critical time. Indicating that turmoil and the fact that Butler was a turning point in the Court’s thinking, in later jurisprudence Butler has been referenced to support expansion of authority under the Spending Clause (e.g., Steward Machine Company v. Davis, 301 U.S. 548 (1937)) and to dissent from such expansion (e.g. South Dakota v. Dole, 483 U.S. 203 (1987), O’Connor dissent.) In her dissent, Justice O’Connor noted that Butler was the last case in which the Supreme Court struck down an Act of Congress as beyond the authority granted by the Spending Clause.

This was part of a series of cases decided by the conservative Supreme Court of the time period which declared unconstitutional parts of Franklin D. Roosevelt's New Deal legislation. Constitutionality is the status of a law, procedure, or act being in accordance with the laws or guidelines contained in a constitution. ... FDR redirects here. ... Wikiquote has a collection of quotations related to: New Deal For other uses of old Deal and The New Deal, see New Deal (disambiguation). ...