Gibbons v. Ogden

Following is the case brief for Gibbons v. Ogden, United States Supreme Court, (1824)

Case Summary for Gibbons v. Ogden:

  • Gibbons was granted permission from Congress to operate steamboats in New York. Ogden was granted a license by the state of New York to operate his steamboat in the same manner.
  • Ogden filed suit for an injunction to prevent Gibbons from operating his steamboats.
  • The Court of Chancery granted the injunction and Gibbons appealed to the United States Supreme Court.
  • The Supreme Court reversed the lower court, holding that Article 1 Section 8 of the Constitution grants Congress the power to regulate interstate commerce.

Gibbons v. Ogden Case Brief

Statement of the facts:

Both Gibbons (Plaintiff) and Ogden (Defendant) operated steamboats in New York in an effort to regulate coastal trade. Gibbons was given permission from the United States Congress, in contrast, Ogden received a license under state law.  In response, Ogden filed suit in the state Court of Chancery to enjoin Gibbons from operating his steamboat in state waters. Gibbons claimed he was validly operating his boats pursuant to an order of Congress and as a result, had exclusive power under the constitution to regulate commerce between the states. The court ruled in favor of Ogden, issuing an injunction to stop Gibbons from operating his steamboats.

Procedural History:

Gibbons appealed the New York Court of Chancery decision to the New York Court of Errors. The Court of Errors affirmed and Gibbons appealed to the United States Supreme Court.

Issue and Holding:

Can states regulate interstate commerce within its borders when Congress also regulates the same area of interstate commerce? No.

Rule of Law or Legal Principle Applied:

When Congress and a state pass conflicting laws which regulate interstate commerce, the federal law will govern under Congresses grant of power to regulate interstate commerce under the Constitution.

Judgment:

The decision of the Court of Errors is reversed.

Reasoning:

Commerce includes intercourse and navigation, traffic and commodities in interstate commerce.  Article 1 section 8 of the Constitution grants Congress the power to regulate interstate commerce. Congress may also regulate all commercial activity occurring amongst different states, but not within the state (intrastate).

This power includes the ability to regulate the interstate commercial activity of steamboats in navigable waters in the state of New York. As a result of congresses power to regulate interstate commerce, the federal supremacy clause mandates that federal regulation trumps state regulation. The New York law regulating interstate commercial activity is unconstitutional and Gibbons should not be prohibited from operating steamboats in the state.

Concurring/Dissenting opinion:

Concurring (Johnson):

The grant of power in the constitution to Congress is absolute. When the framers gave Congress the power to regulate commerce, they also gave it the power to regulate all of the subsidiary activities that accompany the rights such as carrying trade, shipbuilding and propagating seaman.

Significance:

Gibbons v. Ogden is extremely relevant because it established Congresses right to regulate interstate commerce. In addition, it held the powers designated to Congress in Article 1 Section 8 of the United States Constitution as supreme to conflicting state law which attempt to regulation interstate commerce.

Student Resources:

http://www.pbs.org/wnet/supremecourt/antebellum/landmark_gibbons.html
https://www.law.cornell.edu/supremecourt/text/22/1

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