Until 1937, the Supreme Court held that the Commerce Clause gave Congress the power to regulate only interstate commerce, such as an interstate telegraph message.

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This is known as the "pre-New Deal" interpretation of the Commerce Clause. In 1937, the Supreme Court adopted a broader interpretation that allowed Congress to regulate even purely intrastate economic activity if it had a substantial effect on interstate commerce.

Until 1937, the Supreme Court Held That the Commerce Clause