The Daniel Ball
77 U.S. 557 (1870)
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Rule of Law:
Commerce includes the transportation of goods on a journey from one state to another, and any transportation that forms a part of that journey is subject to congressional regulation, even if a particular carrier operates solely within the boundaries of a single state. Navigable waters of the United States are those that are navigable in fact and form a continuous highway for commerce with other states or foreign countries.
Facts:
- A steamer named The Daniel Ball was engaged in transporting merchandise and passengers on the Grand River in Michigan.
- The steamer's route was entirely within the state of Michigan, operating between the cities of Grand Rapids and Grand Haven.
- The Grand River is a navigable waterway that flows into Lake Michigan, creating a continuous water highway to other states and foreign countries.
- The Daniel Ball transported goods that were shipped from Grand Rapids and destined for states other than Michigan.
- The steamer also transported goods that originated in other states and were destined for places within Michigan.
- The Daniel Ball was not operating in connection with any specific interstate railway or steamship line.
- The steamer operated without a license to carry on this trade and without having been inspected, as required by acts of Congress.
Procedural Posture:
- The United States filed a libel in the District Court for the Western District of Michigan against the steamer Daniel Ball for violating acts of Congress requiring a license and inspection.
- The District Court, a federal trial court, dismissed the libel and entered a decree for the claimant (the owner of the steamer).
- The United States, as appellant, appealed the decision to the Circuit Court for the Western District of Michigan.
- The Circuit Court, an intermediate federal appellate court, reversed the decree of the District Court and entered a decree for the United States.
- The claimant, as appellant, appealed the Circuit Court's decision to the Supreme Court of the United States.
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Issue:
Does Congress have the authority under the Commerce Clause to regulate a steamship that operates exclusively on a navigable waterway within a single state, if that ship transports goods destined for or originating from other states as part of a larger journey of interstate commerce?
Opinions:
Majority - Justice Field
Yes. A steamer operating on an intrastate route is subject to federal regulation under the Commerce Clause if it is an instrument in the larger stream of interstate commerce. The court established two key principles. First, it defined 'navigable waters of the United States' not by the common law tide-water test, but as waters that are navigable in fact and that form a continuous highway for interstate or foreign commerce. The Grand River meets this test because it is used for transport and flows into Lake Michigan, connecting it to other states. Second, the court held that the character of commerce is determined by the origin and destination of the goods, not the route of any single carrier. Because The Daniel Ball was carrying goods moving in interstate commerce, it was an instrument of that commerce and thus subject to the authority of Congress, even though the vessel itself never left Michigan.
Analysis:
This case significantly expanded the scope of federal power under the Commerce Clause by establishing the 'stream of commerce' doctrine. By focusing on the interstate journey of the goods rather than the intrastate route of the carrier, the Court enabled federal regulation of activities that were seemingly local. It also modernized the definition of 'navigable waters of the United States' from the English tidal test to a more practical 'navigable-in-fact' standard, bringing nearly all commercially significant inland waterways under federal jurisdiction. This decision provided a foundational principle for future expansions of federal regulatory power over transportation and commerce.
