Held:  Congress may not regulate intrastate instrumentalities production –
production is not commerce. The power to regulate commerce is not a congressional
police power. Congress can regulate only those things that directly affect or are
directly a part of interstate commerce.
This case is distinguished from the Lottery case and others like it that
prohibited transportation in interstate commerce. In those cases, the interstate
transportation itself was necessary to the accomplishment of the harmful results.
Here the goods themselves are harmless. Manufacturing is purely a local activity
and as such can be subject only to local regulation.