Gibbons v. Ogden
22 U.S. (9 Wheat.) 1 (1824)
Constitutional Topic Areas:
Article I §8 Clause 3 ‘Commerce Clause’, Enumerated powers, Appellate Jurisdiction, Federalism
Case Facts:
In 1798, the New York State Legislature authorized Robert R. Livingston (inventor of the steamboat) and Robert Fulton’s business North River Steamboat exclusive rights for all steamboat traffic within the state, namely the Hudson River. This effectively created a monopoly on steamboat traffic within the state, encouraging them to pursue other legislature-granted monopolies in other locations. The Orleans Territory (currently the State of Louisiana) granted them another monopoly on the lower Mississippi River. This action prompted competitors to challenge the legality of these monopolies, which then prompted Livingston and Fulton to undercut their competition by selling franchises for their routes and buying up competitor’s ships. In 1815, Aaron Ogden, the former governor of New Jersey, wanted to use these routes for his own business purposes but was forced to purchase a franchise of North River Steamboat rather than operate under his own business. Ogden subsequently entered into a business partnership with Thomas Gibbons, another steamboat proprietor. Three years later in 1818, Ogden and Gibbons’ partnership failed when Gibbons operated a steamboat on Ogden’s franchised route between New York and New Jersey. According to the New York Legislature, only North River Steamboat and its franchisees could operate this route. Gibbons argued he was legally able to operate the route without North River Steamboat’s license because the US Congress’ had licensed him to operate under a 1793 law which regulated the US coastal trade. In 1820, Ogden sued Gibbons in New York where a permanent injunction was rendered to Gibbons on the basis that states share concurrent power with Congress on issues pertaining to interstate commerce. Gibbons appealed to the Supreme Court arguing that Congress had exclusive power over interstate commerce according to Article 1 §8 Clause 3 of the Constitution.
Questions:
1. Does Article 1 §8 Clause 3 of the US Constitution grant Congress national supremacy over states rights in cases of interstate commerce?
2. Is New York’s 1798 law granting North River Steamboat their monopoly unconstitutional?
Holding:
1. Yes
2. Yes
Legal Reasoning: Chief Justice J. Marshall (Unanimous)
1. The Constitution explicitly enumerates Congress’ power to regulate all interstate commerce. This includes the broad definition of ‘commerce’ which includes navigation
2. Since Congress’ power reigns supreme to state laws, the 1798 law is unconstitutional because it allows the State of New York to control interstate commerce independently
Significance:
The courts holding substantially empowered the federal government’s regulatory abilities across all states, further solidifying its supremacy over states rights. After Gibbons, steamboat operators and other logistics businesses had to be licensed only by the federal government, rather than needing to go through state’s legislatures or other venues. Furthermore, Gibbons became the foundation for numerous future court cases involving interstate commerce
Reflection:
Many landmark Supreme Court cases such as Heart of Atlanta Motel, Inc. v. US, Wickard v. Filburn, US v. Lopez, etc. were predicated on Gibbons. These cases molded American society beyond interstate commerce on its face and continue to do so. Overall, Gibbons broadened the power of the federal government
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