Gibbons v. Ogden

Supreme Court of the United States
6 L.Ed. 23, 9 Wheat. 1 (1824)

ELI5:

Rule of Law:

Under the Supremacy Clause, a state law that conflicts with a valid federal law enacted pursuant to the Commerce Clause is unconstitutional and void. The power to regulate interstate commerce, which includes navigation, is a power granted to the U.S. Congress.

Facts:

The New York Legislature granted Robert Livingston and Robert Fulton the exclusive right to operate steamboats within New York waters for a term of years.
Livingston and Fulton assigned to Aaron Ogden the right to navigate the waters between New York City and certain places in New Jersey.
Thomas Gibbons, a competitor of Ogden, began operating two steamboats, the Stoudinger and the Bellona, on a route between New York City and Elizabethtown, New Jersey.
Gibbons' steamboats were duly enrolled and licensed to be employed in the 'coasting trade' under an act of the United States Congress.
Ogden asserted that Gibbons' operation of steamboats violated the exclusive privilege granted to him under the New York state law.

Procedural Posture:

Aaron Ogden filed a bill against Thomas Gibbons in the Court of Chancery of New-York, the trial court.
The Chancellor of New York granted an injunction restraining Gibbons from operating his steamboats in New York waters.
Gibbons appealed the Chancellor's decree to the Court for the Trial of Impeachments and Correction of Errors of the State of New-York, which was the highest court of law and equity in the state.
The highest state court affirmed the decree of the Chancellor.
Gibbons then brought the case to the United States Supreme Court by appeal.

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Issue:

Does a New York law granting an exclusive right to navigate state waters by steamboat violate the Commerce Clause of the United States Constitution when it conflicts with a federal law licensing vessels for the coasting trade?

Opinions:

Majority - Chief Justice Marshall

Yes, the New York law is repugnant to the Constitution and void. The power to regulate commerce among the several states is granted to Congress by the Commerce Clause and includes the power to regulate navigation. The term 'commerce' is not limited to traffic or the exchange of commodities, but describes all commercial intercourse, which necessarily includes navigation. The phrase 'among the several States' means that congressional power extends into the interior of states, not stopping at their external boundaries, so long as the commerce concerns more than one state. When a state law conflicts with a federal law enacted in pursuance of the Constitution, the federal law is supreme. In this case, Gibbons' vessels were licensed under a federal act for carrying on the coasting trade, which grants a federal permission to engage in that trade. The New York law prohibiting such navigation by steamboat is in direct collision with this federal act and must yield.

Concurring - Justice Johnson

Yes, the New York law is unconstitutional. The power of Congress to regulate interstate commerce is exclusive, meaning the states have no authority to legislate in this area at all, even in the absence of conflicting federal law. The grant of this power to Congress was intended to be complete and to prevent the states from creating the very kind of partial and invidious commercial restraints that this New--York monopoly represents. Therefore, the state law is void not merely because it conflicts with the federal licensing act, but because the state lacks any power to create such a regulation of interstate commerce in the first place.

Analysis:

Gibbons v. Ogden is a landmark decision that fundamentally shaped the interpretation of the Commerce Clause and the balance of power between federal and state governments. By defining 'commerce' broadly to include navigation and intercourse, the Court established a wide scope for federal regulatory authority. This decision prevented states from enacting protectionist legislation that would hinder the free flow of goods and services, thereby laying the constitutional foundation for a unified national market. The case affirmed the principle of federal supremacy, making it clear that state laws must yield when they conflict with federal statutes validly enacted under the Constitution.

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