Gibbons v. Ogden

Gibbons v. Ogden Summary

The Supreme Court ruled in favor of Gibbons, who was in possession of a federal license for the “coasting trade”, and asserted that his right to transport passengers across the New York-Elizabethtown waterway superseded that of Ogden, who merely possessed a New York State license authorizing him to transport a steam-boat across the waterway. This was because, under the Commerce Clause, the federal government maintained the power to regulate interstate commerce, including the “coasting trade” and other transportation across waterways.

Key Players in Gibbons v. Ogden

• 1Appellants: Gibbons, possessor of a federal license for “coasting trade” which granted him a right to travel along the New York-Elizabethtown waterway path.
• 2Appellees: Ogden, possessor of a New York State steam-boat license which granted exclusive rights to transport passengers along the waterway between New York and Elizabethtown.

Gibbons v. Ogden Brief

The central theme of this case was the power reserved by the Constitution to the federal government to regulate interstate commerce through the Commerce Clause.

Gibbons v. Ogden Facts

Ogden claimed that, by virtue of a New York State steam-boat license, he possessed exclusive rights to transportation between New York and Elizabethtown and that those rights were being infringed upon by a Gibbons, who was trying to operate steam-boats 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-Elizabethtown path. Ogden tried to file an injunction to prevent Gibbons from using the same waterway. The lower court upheld the injunction granted to Ogden, and Gibbons then filed an appeal claiming that the New York regulation of waterway licenses was unconstitutional as a violation of the Commerce Clause.

The Gibbons v. Ogden Decision

The outcome of this case was a ruling in favor of the appellant based on the Court’s finding that the appellant and the appellee’s trade amounted to interstate commerce and that, 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.

The Court concluded that navigation was a “trade” across state lines and was, thus, part of interstate commerce. Because of that, the Court reasoned that the federal government held the exclusive right to regulate the licenses and rights to travel across the New York-Elizabethtown waterway. It noted that no “concurrent power” rested in the states when the federal government regulated interstate commerce. That is, it recognized that the power to regulate interstate commerce is “concurrent” until Congress acts to regulate an instrument of interstate commerce. The Court detailed that the basis for that requirement in the Commerce Clause was the desire, in the 1780s, to establish a “uniform” body of trade regulations. The Court acknowledged how, under the Supremacy Clause of the Constitution, Congressional acts superseded state laws. It detailed how this was the case even if the subject of the law was within the state’s power to regulate. In that way, Gibbons’ federal license superseded Ogden’s New York state license. Ogden was not granted the injunction against Gibbons.

The Court’s ruling also addressed the argument that the scenario in this case—that of concurrent state and federal waterway licenses—was analogous to the case of concurrent state and federal patents. The appellees had argued that, because states can award patents and have them recognized as valid, states can also award waterway licenses and have them recognized as valid. The Court did not explicitly rule on that issue but suggested that the case of patents was not a valid analogy. It reasoned that, while states may generally have the right to issue patents as rights in specific property, the state in the instant case was seeking to grant a right in something that was inextricably linked to interstate commerce.

Key Takeaways for Law Students

• 1The power to regulate interstate commerce is reserved for the federal government by the Constitution under the Commerce Clause.
• 2The “coasting trade” or other transport across water (across state lines) qualifies as “interstate commerce” such that the power to regulate it is reserved for the federal government.