Gibbons v. Ogden
United States Supreme Court
22 U.S. (9 Wheat.) 1 (1824)
Rule of Law
If a state and Congress both pass conflicting laws regulating interstate commerce, the federal law governs pursuant to Congress’s constitutional grant of power to regulate interstate commerce.
Ogden (plaintiff) received a license under New York state law that purported to give him the exclusive right to operate steamboats in New York waters. Gibbons (defendant) sought and obtained a similar license from the federal government, which Gibbons used to compete with Ogden in the same water route that Ogden was using. To protect his monopoly license, Ogden filed suit in the New York Court of Chancery to enjoin Gibbons from operating his boats in New York waters. Gibbons argued that he was operating his boats pursuant to an order of Congress, and that Congress has exclusive power under Article I, Section 8 of the Constitution to regulate interstate commerce. The New York Court of Chancery found in favor of Ogden and issued an injunction to restrict Gibbons from operating his boats. Gibbons appealed the case to the Court of Errors of New York, which affirmed the decision. Gibbons appealed to the United States Supreme Court.
If a state and Congress both pass conflicting laws regulating interstate commerce, does the state law govern?
Holding and Reasoning (Marshall, C.J.)
No. Congress is granted the power to regulate interstate commerce in Article I, Section 8 of the Constitution. The word “commerce” includes traffic, intercourse, and navigation, as well as commodities associated with interstate commerce. Congress may regulate all commercial activities occurring between states but not activities occurring solely within one state’s borders. If a state and Congress both pass conflicting laws regulating interstate commerce, the federal law governs pursuant to Congress’s constitutional grant of power to regulate interstate commerce. In this case, Congress has the power to regulate the interstate commercial activity of steamboats on navigable waters within the state of New York. Because Congress has the power to regulate this activity, and New York passed conflicting regulations of the same activity, federal supremacy principles dictate that the federal regulation trumps the state regulation. Thus, the New York regulatory law is deemed unconstitutional. The decision of the Court of Errors prohibiting Gibbons from operating steamboats in New York is reversed.
Concurrence (Johnson, J.)
The only issue that ultimately needs to be determined is the intent of the framers in construing Congressional powers. The grant of power by the framers to Congress to regulate interstate commerce is absolute. Additionally, when the framers gave Congress the power to regulate commerce, they gave it the power to regulate all subsidiary activities that accompany it, such as shipbuilding, carrying trade, and the propagation of seamen. Gibbons’ power to run his boats is derived from the framers’ intent to accord Congress the power to regulate all areas of interstate commerce, not the states.