The Supreme Court Case of Gibbons v. Ogden

Gibbons v. Ogden Defined Interstate Commerce

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The case of Gibbons v. Ogden, decided by the U.S. Supreme Court in 1824, was a major step in the expansion of the power of the federal government to deal with challenges to U.S. domestic policy. The decision confirmed that the Commerce Clause of the Constitution granted Congress the power to regulate interstate commerce, including the commercial use of navigable waterways. 

Circumstances of Gibbons v. Ogden

In 1808, the state government of New York awarded a private transport company a virtual monopoly to operate its steamboats on the state’s rivers and lakes, including rivers that ran between New York and adjoining states.

This state-sanctioned steamboat company granted Aaron Ogden a license to operate steamboats between Elizabethtown Point in New Jersey and New York City. As one of Ogden’s business partners, Thomas Gibbons, operated his steamboats along the same route under a federal coasting license issued to him by an act of Congress.

The Gibbons-Ogden partnership ended in dispute when Ogden claimed that Gibbons was undercutting their business by unfairly competing with him.

Ogden filed a complaint in the New York Court of Errors seeking to stop Gibbons from operating his boats. Ogden argued that the license granted to him by the New York monopoly was valid and enforceable even though he operated his boats on shared, interstate waters. Gibbons disagreed arguing that the U.S. Constitution gave Congress the sole power over interstate commerce.

The Court of Errors sided with Ogden. After losing his case in another New York court, Gibbons appealed the case to the Supreme Court, which ruled that the Constitution grants the federal government the overriding power to regulate how interstate commerce is conducted.

Some of the Parties Involved

The case of Gibbons v. Ogden was argued and decided by some of the most iconic lawyers and jurists in U.S. history. Exiled Irish patriot Thomas Addis Emmet and Thomas J. Oakley represented Ogden, while U.S. Attorney General William Wirt and Daniel Webster argued for Gibbons.

The decision of the Supreme Court was written and delivered by America’s fourth Chief Justice John Marshall.

“. . . Rivers and bays, in many cases, form the divisions between States; and thence it was obvious, that if the States should make regulations for the navigation of these waters, and such regulations should be repugnant and hostile, embarrassment would necessarily happen to the general intercourse of the community. Such events had actually occurred, and had created the existing state of things.”  — John Marshall — Gibbons v. Ogden, 1824

The Decision

In its unanimous decision, the Supreme Court ruled that Congress alone had the power to regulate interstate and coastal trade.

The decision answered two pivotal questions about the Constitution’s Commerce Clause: First, exactly what constituted “commerce?” And, what did the term “among the several states” mean?

The Court held that “commerce” is the actual trade of commodities, including the commercial transportation of commodities by means of navigation. In addition, the word “among” meant "intermingled with” or cases in which one or more states had an active interest in the commerce involved.

Siding with Gibbons, the decision read, in part:  

"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."

Significance of Gibbons v. Ogden 

Decided 35 years after the ratification of the Constitution, the case of Gibbons v. Ogden represented a significant expansion of the power of the federal government to address issues involving U.S. domestic policy and the rights of the states.

The Articles of Confederation had left the national government virtually powerless to enact policies or regulations dealing with the actions of the states. In the Constitution, the framers included the Commerce Clause in the Constitution to address this problem.

Though the Commerce Clause gave Congress some power over commerce, it was unclear just how much. The Gibbons decision clarified some of these issues.

John Marshall’s Role

In his opinion, Chief Justice John Marshall provided a clear definition of the word “commerce” and the meaning of the term, “among the several states” in the Commerce Clause. Today, Marshall’s is regarded as the most influential opinions concerning this key clause.​

"... Few things were better known, than the immediate causes which led to the adoption of the present constitution ... that the prevailing motive was to regulate commerce; to rescue it from the embarrassing and destructive consequences, resulting from the legislation of so many different States, and to place it under the protection of a uniform law.”  — John Marshall — Gibbons v. Ogden, 1824

Updated by Robert Longley

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Longley, Robert. "The Supreme Court Case of Gibbons v. Ogden." ThoughtCo, Jun. 14, 2018, thoughtco.com/gibbons-v-ogden-court-case-104788. Longley, Robert. (2018, June 14). The Supreme Court Case of Gibbons v. Ogden. Retrieved from https://www.thoughtco.com/gibbons-v-ogden-court-case-104788 Longley, Robert. "The Supreme Court Case of Gibbons v. Ogden." ThoughtCo. https://www.thoughtco.com/gibbons-v-ogden-court-case-104788 (accessed June 18, 2018).