To access this feature, please Log In or Register for your Casebriefs Account.

Add to Library




Gibbons v. Ogden

Citation. 22 U.S. 1, 9 Wheat. 1, 6 L. Ed. 23 (1824)
Law Students: Don’t know your Studybuddy Pro login? Register here

Brief Fact Summary.

Ogden had a monopoly to operate steamboats in a certain area in New York and New Jersey. Gibbons operated steamboats there as well, so Ogden sought injunctive relief against Gibbons.

Synopsis of Rule of Law.

Congressional power under the Commerce Clause is broad, encompasses all of the commercial intercourse between and among states.


Gibbons’ steamboats were licensed by a federal statute and he operated them between New York and New Jersey. Ogden was granted a monopoly by the state of New York to operate steamboats between New York and New Jersey. Gibbons’ actions violated this monopoly. Ogden obtained injunctive relief against Gibbons from a New York court.


Does the monopoly granted by New York conflict with the federal statute licensing Gibbons’ steamboats?


Yes, Ogden’s monopoly conflicted with the federal statute, and therefore violated the Supremacy Clause.
The Commerce Clause is a broad power granted to Congress in the Constitution. Under this Clause, Congress could regulate all, “commerce which concerns more States than one.” Ogden argued that the New York monopoly grant was superior to the federal statute. The Court, however, explained that powers under the Commerce Clause extend to state action that affected or was connected to commercial activity within another state.
Ogden argued that the 10th Amendment of the Constitution was an independent limit on Congressional power under the Commerce Clause, and this argument was rejected. “[N]o area of interstate commerce is reserved for state control.”
Gibbons also argued that the Commerce power was exclusive, and that states could never decide a matter relating to national commerce. The majority opinion, however, implied that if there was no actual conflict between a state’s action and a Congressional act, then the state could form legislation relating to commerce.


This was the first major case to analyze the powers of Congress under the Commerce Clause. In so doing, the Court interpreted the powers to be very broad, reaching any activity that affected commerce between or among states.

Create New Group

Casebriefs is concerned with your security, please complete the following