Gibbons v Ogden 1824

Facts

A New York state law gave to individuals the exclusive right to operate steamboats on waters within state jurisdiction. Laws like this one were duplicated elsewhere which led to friction as some states would require foreign (out-of-state) boats to pay substantial fees for navigation privileges. In this case Thomas Gibbons -- a steamboat owner who did business between New York and New Jersey under a federal coastal license -- challenged the monopoly license granted by New York to Aaron Ogden. New York courts consistently upheld the state monopoly.

Question

Did the State of New York exercise authority in a realm reserved exclusively to Congress, namely, the regulation of interstate commerce?

Conclusion

The unanimous Court found that New York's licensing requirement for out-of-state operators was inconsistent with a congressional act regulating the coasting trade. The New York law was invalid by virtue of the Supremacy Clause. In his opinion, Chief Justice John Marshall developed a clear definition of the word commerce, which included navigation on interstate waterways. He also gave meaning to the phrase "among the several states" in the Commerce Clause. Marshall's was one of the earliest and most influential opinions concerning this important clause. He concluded that regulation of navigation by steamboat operators and others for purposes of conducting interstate commerce was a power reserved to and exercised by the Congress. In a concurring opinion, Justice William Johnson argued a much stronger position: that the national government had exclusive power over interstate commerce, negating state laws interfering with the exercise of that power. Justice Thomspon did not participate in the discussion or decision of the case.