Gibbons v. Ogden
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| Gibbons v. Ogden | |
| Reference: 22 U.S. 1 | |
| Term: 1824 | |
| Important Dates | |
| Argued: Feb 5-9, 1824 Decided: March 2, 1824 | |
| Majority | |
| Chief Justice John Marshall • Thomas Todd • Gabriel Duvall • Joseph Story• Bushrod Washington | |
| Concurring | |
| William Johnson | |
Gibbons v. Ogden was a case decided on March 2, 1824, by the United States Supreme Court in which the court ruled that Congress has the constitutional power to regulate interstate commerce under the Commerce Clause of the U.S. Constitution. The court found that the state of New York could not grant monopoly navigation rights to interstate waterways that ran through the state.[1]
Why it matters: Gibbons v. Ogden established the precedent that Congress—not the states—has the authority to regulate interstate commerce. The court held that the federal government has the exclusive power to regulate interstate commerce with respect to the nation's navigable waters. State efforts to grant exclusive privileges to navigate in-state waters thus unconstitutionally prohibit out-of-state sailors from freely navigating interstate waters.[2]
Background
After Robert Livingston and Robert Fulton invented the fastest steamboat, the state of New York granted them thirty-year rights to navigate all waters within the jurisdiction of the state. The state of New York's grant of navigation rights excluded others from navigating those same waters, according to Livingston and Fulton, who leased navigation rights to other individuals. Leaseholder Aaron Ogden was permitted to navigate from New Jersey to New York. Ogden’s competitor, Thomas Gibbons, already held a federally granted license to operate those waters. Ogden filed a complaint asking the courts to stop Thomas Gibbons from operating boats for commercial use from New Jersey to New York.[3]
Ogden originally filed the challenge as a patent case, arguing that Gibbons had infringed on Livingston and Fulton's navigable water rights. The central conflict in the case, however, later questioned whether the state of New York had the right to grant the monopoly on interstate waterways.[4]
Ogden claimed that he had exclusive navigable water rights granted to him by the state of New York. Gibbons claimed similar rights granted by the federal government, citing the 1793 Act of Congress, which regulated coastal commerce.[5]
The New York Court of Chancery in 1819 ruled that Aaron Ogden had the right to operate exclusively in the waters between New York and New Jersey.[3] The Supreme Court of the State of New York upheld the lower court decision.[5]
Oral argument
Oral argument was held from February 5 through February 9, 1824. The case was decided on March 2, 1824.[4]
Decision
The Supreme Court decided 6-0 that the New York state law granting monopoly navigation rights was unconstitutional and that the federal government has authority over interstate commerce.
Justice John Marshall wrote the majority opinion and was joined by Justices Thomas Todd, Gabriel Duvall, Joseph Story, and Bushrod Washington.
Justice William Johnson wrote a concurring opinion.
Justice Smith Thompson was absent when the Supreme Court decided Gibbons v. Ogden.[4]
Opinions
Majority opinion
The Supreme Court of the United States held that the New York state law granting exclusive steamboat navigation rights within the state was unconstitutional because the federal government has the exclusive authority to regulate and grant contracts for interstate waterways.[4]
The ruling addressed the following two main questions:
- Did the State of New York law violate Congress' authority to regulate commerce?
- Was New York State law inconsistent with patent law?
Six justices ruled in favor of Gibbons and argued that the state of New York could not grant exclusive rights to navigate waterways. Although Ogden argued on grounds of patent law, the case was decided according to the Commerce Clause. Justice Marshall argued that because Gibbons held a federal coasting license, he was permitted to sail any of the waters of the United States. Furthermore, Marshall argued that federal law invalidated state law. Marshall did not address the patent issue at all, saying that it was not necessary.[4]
Justice Marshall argued that New York's state law deprived others of freely using steam vessels to navigate the waters and that the state law was in conflict with the federal government's sovereign authority to regulate interstate waterways:
| “ | This act demonstrates the opinion of Congress that steamboats may be enrolled and licensed, in common with vessels using sails. They are, of course, entitled to the same privileges, and can no more be restrained from navigating waters and entering ports that are free to such vessels, than if they were wafted on their voyage by the agency of winds, instead of being propelled by the agency of fire. The one element may be as legitimately used as the other, for every commercial purpose authorized by the laws of the Union; and the act of a state inhibiting the use of either to any vessel having a license under the act of Congress comes, we think, in direct collision with that Act.[6] | ” |
Concurring opinion
Justice William Johnson wrote a concurring opinion and agreed that the federal government has exclusive authority over interstate commerce. He also argued that all state laws interfering with federal regulation of interstate commerce could be struck down as unconstitutional.[1]
In his concurring opinion Justice Johnson considered whether the Constitution should be construed strictly or loosely:
| “ | In attempts to construe the constitution, I have never found much benefit resulting from the inquiry, whether the whole, or any part of it, is to be construed strictly, or literally. The simple, classical, precise, yet comprehensive language, in which it is couched, leaves, at most, but very little latitude for construction; and when its intent and meaning is discovered, nothing remains but to execute the will of those who made it, in the best manner to effect the purposes intended. The great and paramount purpose, was to unite this mass of wealth and power, for the protection of the humblest individual; his rights, civil and political, his interests and prosperity, are the sole end; the rest are nothing but the means. But the principal of those means, one so essential as to approach nearer the characteristics of an end, was the independence and harmony of the States, that they may the better subserve the purposes of cherishing and protecting the respective families of this great republic. | ” |
Legacy
| Federalism |
|---|
| •Key terms • Court cases •Major arguments • State responses to federal mandates • Federalism by the numbers • Index of articles about federalism |
The ruling in Gibbons v. Ogden asserted Congress' authority to regulate interstate commerce based on the Commerce Clause. It set a precedent that Congress had the power to overturn state regulations if interstate commerce was involved. For example, if a factory participated in interstate commerce, Congress not only had the power to regulate how the goods were sold, but they also had the power to regulate certain factory conditions, like the payment of minimum wage.[5]
The Gibbons v. Ogden decision stated that Congress' commerce power "is complete in itself, may be exercised to its utmost extent, and acknowledges no limitations, other than are prescribed in the constitution," according to an analysis by SCOTUSblog.[7] In later years, the court specified that interstate commerce had to occur between two or more states. The ruling did not apply to foreign commerce, trade with Indian nations, manufacturing, or the regulation of child labor, according to the Cato Institute.[4]
See also
- John Marshall
- United States Supreme Court
- Wayman v. Southard
- Interstate Commerce Act
- Sherman Anti-Trust Act
- J.W. Hampton Jr. & Co. v. United States
- A.L.A. Schechter Poultry Corp. v. United States
- Wickard v. Filburn
- United States v. Lopez
External links
Footnotes
- ↑ 1.0 1.1 Oyez, “Gibbons v. Ogden,” accessed August 1, 2022
- ↑ Google Books, "John Marshall: Definer of a Nation," accessed June 7, 2022
- ↑ 3.0 3.1 Street Law, “How the case Moved Through the Court System,” accessed December 5, 2013
- ↑ 4.0 4.1 4.2 4.3 4.4 4.5 CATO, “Kids, Guns, and the Commerce Clause: Is the Court Ready for Constitutional Government?” accessed December 5, 2013
- ↑ 5.0 5.1 5.2 PBS, “Landmark Cases: Gibbons v. Ogden (1924)," accessed August 1, 2022
- ↑ 6.0 6.1 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
- ↑ SCOTUSblog, "The simple case for the Affordable Care Act’s constitutionality," August 3, 2011
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