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.
After someone was given an exclusive ferry operations license by a state, a competitor challenged the license as a violation of the Commerce Clause.
Synopsis of Rule of Law.
Commerce that is connected to more than one state is within the reach of Congress’s commerce power.
The Defendant Ogden (Defendant) ran a steamboat service in New York with an exclusive license granted by the state. The Plaintiff Gibbons (Plaintiff) had a similar license granted by Congress. Plaintiff began competing with the Defendant. The Defendant received an injunction to stop Plaintiff’s steamboat service. The Plaintiff appealed.
May a state adopt legislation regarding interstate commerce that conflicts with the Commerce Clause?
No. Judgment reversed.
Under the Commerce Clause, Congress can legislate with regard to all commerce between states. Commerce includes commercial intercourse, not just buying and selling.
Congressional regulation of interstate commerce includes the ability to regulate matters occurring within one state, as long as the activity has some sort of connection with another state. Here, the steamboat started in New York and ended in New Jersey, so it was within reach of the commerce power.
States have no independent control over interstate commerce. When a state law conflicts with a valid federal statute, the state law will violate the Supremacy Clause and be deemed invalid.
The Commerce Clause allows Congress to regulate all commerce that affects more than one state. Also, the Commerce Clause limits a state’s ability to regulate interstate commerce, which is known as the dormant commerce clause.