Gibbons v. Ogden

Citation. 22 U.S. (9 Wheat.) 1, 6 L.Ed. 23 (1824).

Brief Fact Summary.

Ogden claimed to possess exclusive rights to a waterway between New York and New Jersey, by virtue of a New York State steamboat license. Gibbons operated in the same waterway, by virtue of a federal statute. Ogden sued to prevent Gibbons from using the same waterway.

Synopsis of Rule of Law.

The power to regulate interstate commerce is reserved for the federal government by the Constitution under the Commerce Clause.

Facts.

Ogden claimed that, by virtue of a New York State steamboat license, he possessed exclusive rights to transportation between New York and New Jersey and that those rights were being infringed upon by Gibbons, who was operating steamboats on the same path. Gibbons was licensed to participate in the “coasting trade” under a federal statute and claimed that that federal license gave him the right to navigate the New York-New Jersey path. Ogden obtained an injunction to prevent Gibbons from using the same waterway. Gibbons appealed, arguing that the New York law purporting to give exclusive privilege of the waterway to Ogden conflicts with the Commerce Clause.

Issue.

Does the New York law purporting to give exclusive privilege of the waterway to Ogden conflict with the Commerce Clause?

Held.

Yes, because Ogden’s trade amounted to interstate commerce.

Discussion.

Because Ogden’s trade amounted to interstate commerce, under the Commerce Clause, such a trade could only be regulated by Congress and not by the state of New York. The Court found that New York State’s regulation of licenses for navigation was unconstitutional because it allotted the power to regulate interstate commerce to a state when the Commerce Clause reserved that power for the federal government. The Court examined whether mere transportation across water—which the court called “navigation”—constituted a “trade” such that regulation of it fell under the power to regulate interstate commerce.