Gibbons v. Ogden case brief summary
22 U.S. 1 (1824)
Overview
A dispute arose as to the regulation of the oper- ation of steamboats by the State of New York.
Facts
New York had granted Robert Livingston and Robert Fulton the exclusive right to operate steamboats between New York and New Jersey. Livingston and Fulton then assigned this right to Ogden. When Gibbons established competing steamboat routes, Ogden sued for enforcement of his monopoly rights. Gibbons responded by stating that a federal statute authorized him to navigate the routes in question.
Issue
Should Gibbons be allowed to operate his steamboats notwithstanding the monopoly granted by New York?
Holding
Gibbons should be allowed to operate his steam- boats.
Reasoning
Marshall, C.J. In attempting to create a monopoly on interstate navigation, New York has intruded upon powers reserved to Congress under the Commerce Clause. The Clause states that Congress has the power to regulate “commerce” without qualifying the grant of power with any restrictions. Ogden therefore takes an overly narrow view of the Clause in arguing that “commerce” should be interpreted to refer only in the traffic of goods as contrasted with navigation in general.
22 U.S. 1 (1824)
Overview
A dispute arose as to the regulation of the oper- ation of steamboats by the State of New York.
Facts
New York had granted Robert Livingston and Robert Fulton the exclusive right to operate steamboats between New York and New Jersey. Livingston and Fulton then assigned this right to Ogden. When Gibbons established competing steamboat routes, Ogden sued for enforcement of his monopoly rights. Gibbons responded by stating that a federal statute authorized him to navigate the routes in question.
Issue
Should Gibbons be allowed to operate his steamboats notwithstanding the monopoly granted by New York?
Holding
Gibbons should be allowed to operate his steam- boats.
Reasoning
Marshall, C.J. In attempting to create a monopoly on interstate navigation, New York has intruded upon powers reserved to Congress under the Commerce Clause. The Clause states that Congress has the power to regulate “commerce” without qualifying the grant of power with any restrictions. Ogden therefore takes an overly narrow view of the Clause in arguing that “commerce” should be interpreted to refer only in the traffic of goods as contrasted with navigation in general.
Unlike the power of taxation, the power to regulate interstate commerce in this case cannot be
exercised concomitantly and harmoniously by
the states and the federal government. In taxation, a state may take its share of the economic
output without interfering with the federal government’s ability to take from the remainder.
In the current case, New York’s attempted regulation of navigation has brought its state law
into conflict with a federal statute. In such a
case, the federal statute must prevail.
Johnson, J. The nature of the power to regulate commerce is such that its grant to Congress must be plenary, leaving no residual power to the states. It is important to note, however, that identity of means does not necessarily imply identity of power. Federal statutes may act on navigation with the end of regulating commerce while state statutes may act on the same navigation with a view toward preventing the spread of disease. No conflict exists as long as the states and the federal government use regulations for sufficiently distinct ends.
Johnson, J. The nature of the power to regulate commerce is such that its grant to Congress must be plenary, leaving no residual power to the states. It is important to note, however, that identity of means does not necessarily imply identity of power. Federal statutes may act on navigation with the end of regulating commerce while state statutes may act on the same navigation with a view toward preventing the spread of disease. No conflict exists as long as the states and the federal government use regulations for sufficiently distinct ends.
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