U.S. v. Butler, 297 U.S. 1 (1936)

This case was decided prior to Wickard v. Filburn. Thus, at the time, Congress did not have the power to directly limit agricultural producers' growing of crops under its Commerce Clause powers.The law at issue in Butler imposed taxes on agricultural producers who exceeded their mandated quota of production on certain crops and used federal funds to pay agricultural producers who agreed not to exceed their quota of production on those crops. The Court found that this exceeded Congress's powers under the Taxing and Spending Clause because it was an indirect way of accomplishing what Congress could not do directly. Now, of course, Congress can regulate these things directly under the Commerce Clause, so by definition Congress could also use its Taxing and Spending Powers to limit the growing of crops. But what is still important about Butler is its interpretation of the scope of Congress's Taxing and Spending powers.