Gibbons v. Ogden
Decided
1824
Facts of the Case
A New York state law gave Robert R. Livingston and Robert Fulton a 20-year monopoly over navigation on waters within state jurisdiction. Aaron Ogden and other competitors tried to forestall the monopoly, but Livingston and Fulton largely succeeded in selling franchise or buying competitors' boats. Thomas Gibbons -- a steamboat owner who did business between New York and New Jersey under a federal coastal license - formed a partnership with Ogden, which fell apart after three years when Gibbons operated another steamboat on a New York route belonging to Ogden. Ogden filed suit against Gibbons in New York state court, and received a permanent injunction The New York state court rejected Gibbons' argument asserting that U.S. Congress controlled interstate commerce.
Provisions of the Constitution
Commerce Clause
Other Opinions
Concurring Opinion: the national government had exclusive power over interstate commerce, negating state laws interfering with the exercise of that power (Justice William Johnson)
Legal Question
Does the Commerce Clause give Congress authority over interstate navigation?
Legal Reasoning
Justice Marshall 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 under the Commerce Clause. As interstate navigation fell under interstate commerce, New York could not interfere with it, and the law was therefore invalid.
What doctrine, standards or policy?
Law became invalid
Statute that Triggered Dispute
New York state law
Outcome
Unconstitutional matter reserved to Congress
