1937 Jones v. Laughlin Steel Corp case, the Court held that “intrastate activities that ‘have a close and substantial relation to interstate commerce that their control is essential or appropriate to protect that commerce from burdens and obstructions’ are within Congress’ power to regulate”;16 later, in the 1942 Wickard v. Filburn decision, it went much further, ruling that withholding goods from interstate commerce affects interstate commerce and therefore such activity is subject to congressional lawmaking power.
