Gibbons v. Ogden (1824) was a Supreme Court case that famously expounded upon the powers of the commerce clause, setting the
precedent of Congress’s broad ability to regulate interstate and some intrastate commerce. The case originated in a dispute over shipping monopolies in New York. Ogden and Gibbons both were in the business of steamboat operations between New York and New
Jersey. Ogden had a monopoly from the state of New York over steamboat operations in state waters, but Gibbons had a federal license to operate within New York. After a New York court granted an injunction against Gibbons, Gibbons appealed up to the Supreme Court which found that Congress
had the ability to regulate the shipping under the commerce clause and therefore superior to the state’s regulations. The case involved many historical figures of business and law including Cornelius Vanderbilt and Daniel Webster. The court decided in this case that the commerce clause allows Congress to regulate not only interstate commerce but also intrastate commerce
(commerce within a state) that substantially impacts interstate commerce. This decision in Gibbons v. Ogden set the foundation for later cases such as Wickard v. Filburn that greatly expanded the ability of Congress to regulate commerce within a state itself. [Last updated in January of 2022 by the Wex Definitions Team]
Annotation Primary Holding The Commerce Clause gives Congress authority over interstate navigation. Facts Seeking a monopoly over navigation on the waters throughout the U.S., Robert R. Livingston and Robert Fulton secured exclusive privileges to the waters in New York for a period of 20 years, as well as the lower Mississippi River. Aaron Ogden and other competitors tried to forestall the monopoly, but Livingston and Fulton largely succeeded in selling franchises or buying boats of competitors. Ogden formed a partnership with Thomas Gibbons, but this fell apart after three years when Gibbons operated another steamboat on a route in New York that belonged to Ogden. When Ogden brought an action against Gibbons in New York state court, he received a permanent injunction. The court rejected an argument by famous lawyer Daniel Webster on behalf of Gibbons, which asserted that the U.S. Congress controlled interstate commerce. The case became one of several reviewed by the U.S. Supreme Court that concerned the proper interpretation of the Commerce Clause in Article I, Section 8 of the Constitution. Attorneys
Opinions Majority
Reversing the state court's grant of a permanent injunction, Marshall agreed with Webster's argument that Congress held exclusive power to regulate commerce among the states. He believed that the definition of "commerce" should be interpreted broadly and that it included navigation. The Supremacy Clause may have guided Marshall's reasoning with regard to his statements that any federal license for navigation should trump any comparable license granted by a state. Concurrence
Recused
Case Commentary This is one of the foundational cases on the broad Congressional powers under the Commerce Clause. Interstate navigation is clearly part of interstate commerce, so states cannot interfere with it by overly regulating the area and creating burdens not imposed by Congress. The case is also notable in that it featured a virtual all-star cast of 19th-century American lawyers, which showed how much was at stake beyond the private dispute.
Gibbons v. Ogden, 22 U.S. (9 Wheat.) 1 (1824), was a landmark decision in which the Supreme Court of the United States held that the power to regulate interstate commerce, which was granted to Congress by the Commerce Clause of the United States Constitution, encompassed the power to regulate navigation.[1][2] The case was argued by some of America's most admired and capable attorneys at the time. The exiled Irish patriot Thomas Addis Emmet and Thomas J. Oakley argued for Ogden, and U.S. Attorney General William Wirt and Daniel Webster argued for Gibbons. Background[edit]In 1798 the New York State Legislature granted to Robert R. Livingston and Robert Fulton exclusive navigation privileges of all the waters within the jurisdiction of that state with boats moved by fire or steam for a term of twenty years. Livingston and Fulton subsequently also petitioned other states and territorial legislatures for similar monopolies in the hope of developing a national network of steamboat lines, but only the Orleans Territory accepted their petition and awarded them a monopoly on the lower Mississippi.[3] Aware of the potential of the new steamboat navigation, competitors challenged Livingston and Fulton by arguing that the commerce power of the federal government was exclusive and superseded state laws. Legal challenges followed, and in response, the monopoly attempted to undercut its rivals by selling them franchises or buying their boats. Former New Jersey Governor Aaron Ogden had tried to defy the monopoly but ultimately purchased a license from a Livingston and Fulton assignee in 1815 and entered business with Thomas Gibbons from Georgia. The partnership collapsed three years later, however, when Gibbons operated another steamboat on Ogden's route between Elizabeth-town, New Jersey (now Elizabeth), and New York City, which had been licensed by the United States Congress under a 1793 law regulating the coasting trade.[4] The partners ended up in the New York Court for the Trial of Impeachments, which granted a permanent injunction against Gibbons in 1820.[3] Case[edit]Aaron Ogden filed a complaint in the Court of Chancery of New York to ask the court to restrain Thomas Gibbons from operating on these waters. Ogden's lawyer contended that states often passed laws on issues regarding interstate matters and should have fully concurrent power with Congress on matters concerning interstate commerce. Gibbons's lawyer, Daniel Webster, argued that Congress had exclusive national power over interstate commerce according to Article I, Section 8, Clause 3, of the Constitution and that to argue otherwise would result in confusing and contradictory local regulatory policies. The Court of Chancery of New York and the Court of Errors of New York found in favor of Ogden and issued an injunction to restrict Gibbons from operating his boats. Gibbons appealed to the Supreme Court and argued, as he had in New York, that the monopoly conflicted with federal law. After several delays, the court began discussing the meaning of the commerce clause in 1824, which by that time had become an issue of wider interest. Congress was debating a bill to provide a federal survey of roads and canals.[5] Southerners, in particular, were growing more sensitive to what result a holding for exclusive federal jurisdiction over commerce would mean to them as sectional disputes, especially over slavery, were increasing.[3] Just 18 months prior to oral arguments in the Gibbons v. Ogden case, the people of Charleston, South Carolina, had been dismayed at the revelation of Denmark Vesey's plotted slave revolt. The statehouse quickly followed up the preemptive suppression of the rebellion with the Negro Seamen Act, requiring free black sailors on ships coming into the state to be jailed for the duration of the ship's stay in port. The act was promptly struck down as unconstitutional by Associate Justice Johnson while he was riding federal circuit on grounds that the act violated commercial treaty provisions with Great Britain. South Carolina emphatically rejected Johnson's holding, and talk quickly emerged of nullification and violent disunion. To thread the needle in the Gibbons case, the Court would need to deliver a holding that both defended national power over interstate commerce but did not eradicate state police powers that Southern whites viewed as vital to their very survival. Decision of Supreme Court[edit]The US Supreme Court ruled in favor of Gibbons. Congress had the right to regulate interstate commerce. The sole decided source of Congress's power to promulgate the law at issue was the Commerce Clause. Accordingly, the Court had to answer whether the law regulated "commerce" that was "among the several states." With respect to "commerce," the Court held that commerce is more than mere traffic and is the trade of commodities. This broader definition includes navigation. The Court interpreted "among" as "intermingled with." "If, as has always been understood, the sovereignty of Congress, though limited to specified objects, is plenary as to those objects, the power over commerce with foreign nations and among the several States is vested in Congress as absolutely as it would be in a single government, having in its Constitution the same restrictions on the exercise of the power as are found in the Constitution of the United States." The part of the ruling which stated that any license granted under the Federal Coasting Act of 1793 takes precedence over any similar license granted by a state is also in the spirit of the Supremacy Clause although the Court did not specifically cite that clause.[citation needed] The Court did not discuss the argument pressed for Gibbons by U.S. Attorney General Wirt that the federal patent laws preempted New York's patent grant to Fulton and Livingston.[6] That question remained undecided for the next 140 years until the Supreme Court held in Sears, Roebuck & Co. v. Stiffel Co. (1964) that federal patent law preempted similar state laws. Opinion excerpts[edit]
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What do both Gibbons v Ogden and McCulloch v Maryland have in common?Both cases involve implied powers: Licensing boats (Gibbons) and chartering a national bank (McCulloch). In both cases, the Interstate Commerce Clause is used at least in part as the justification for the implied power.
What was the Supreme Court case Gibbons v Ogden was related to?After the State of New York denied Gibbons access to the Hudson Bay, he sued Ogden. The case went to the Supreme Court, and Chief Justice Marshall's opinion carried out the clear original intent of the Constitution to have Congress, not the states, regulate interstate commerce.
What is commerce in Gibbons v Ogden?Ogden, 22 U.S. 1 (1824) The Commerce Clause gives Congress authority over interstate navigation. Seeking a monopoly over navigation on the waters throughout the U.S., Robert R.
Who won the case Gibbons v Ogden in 1824 and why?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.
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Which case has the same relationship to the commerce clause as gibbons v. ogden (1824)?
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