The effect of modern specialization on agriculture has been
discussed by the U.S. Supreme Court as follows:
Whether a particular type of activity is agricultural depends, in
large measure, upon the way in which that activity is organized in a
particular society. The determination cannot be made in the abstract. In
less advanced societies the agricultural function includes many types of
activity which, in others, are not agricultural. The fashioning of
tools, the provision of fertilizer, the processing of the product, to
mention only a few examples, are functions which, in some societies, are
performed on the farm by farmers as part of their normal agricultural
routine. Economic progress, however, is characterized by a progressive
division of labor and separation of function. Tools are made by a tool
manufacturer, who specializes in that kind of work and supplies them to
the farmer. The compost heap is replaced by factory produced
fertilizers. Power is derived from electricity and gasoline rather than
supplied by the farmer's mules. Wheat is ground at the mill. In this way
functions which are necessary to the total economic process of supplying
an agricultural produce become, in the process of economic development
and specialization, separate and independent productive functions
operated in conjunction with the agricultural function but no longer a
part of it. Thus the question as to whether a particular type of
activity is agricultural is not determined by the necessity of the
activity to agriculture nor by the physical similarity of the activity
to that done by farmers in other situations. The question is whether the
activity in the particular case is carried on as part of the
agricultural function or is separately organized as an independent
productive activity. The farmhand who cares for the farmer's mules or
prepares his fertilizer is engaged in agriculture. But the maintenance
man in a powerplant and the packer in a fertilizer factory are not
employed in agriculture, even if their activity is necessary to farmers
and replaces work previously done by farmers. The production of power
and the manufacture of fertilizer are independent productive functions,
not agriculture (see Farmers Reservoir Co. v.
McComb, 337 U.S. 755 cf. Maneja v. Waialua, 349 U.S. 254).
