What was the US Supreme Court decision in Gibbons v. Ogden?

Answer 1

(The Article Of Confederation)

In Gibbons v. Ogden, (1824), the court ruled that the Interstate Commerce Clause of Article I gave Congressional power over commerce should extend to the regulation of all aspects of commercial interaction between the states, overriding the state law to the contrary on the basis of the Article VI Supremacy Clause. The decision favored Gibbons.

Explanation

The US Supreme Court found in favor of Gibbons, holding that Congress was specifically granted the right to control commerce between states in the Constitution's Interstate Commerce Clause (Article I, Section 8, Clause 3). Congress had established an intent to exercise this right, to an extent, when they passed the Federal Licensing Act of 1793, but hadn't acted to curtail conflicting state practices. The Supreme Court opinion nullified a New York law that granted Robert Fulton and Robert Livingston an exclusive contract to license transportation of passengers and goods on New York waterways, which the State held was its right under the Tenth Amendment.

According to Chief Justice Marshall, Congress had the exclusive right to make laws regarding trade between the states, and that federal law superseded state laws generally under the Supremacy Clause, and specifically under Article I, Section 8, as well as Section 9, which addresses how the Interstate Commerce Clause limits states' legal powers. (See below)

Gibbons had broad application because many states had carved out water transit monopolies that inhibited free trade and travel between the states. The Supreme Court's ruling in this case has been called "the emancipation proclamation of American commerce" for the role it played in nascent capitalism.

Article I, Section 8, Clause 3

"Congress shall have power to regulate commerce with foreign nations, and among the several States, and with the Indian tribes."

Definition of Commerce to Include Navigation

Marshall wrote: "The subject to be regulated is commerce, and our Constitution being, as was aptly said at the bar, one of enumeration, and not of definition, to ascertain the extent of the power, it becomes necessary to settle the meaning of the word . . . Commerce, undoubtedly, is traffic, but it is something more: it is intercourse. It describes the commercial intercourse between nations, and parts of nations, in all its branches, and is regulated by prescribing rules for carrying on that intercourse. The mind can scarcely conceive a system for regulating commerce between nations which shall exclude all laws concerning navigation, which shall be silent on the admission of the vessels of the one nation into the ports of the other, and be confined to prescribing rules for the conduct of individuals in the actual employment of buying and selling or of barter."

Article I, Section 9, Prohibition on States Regulating Each Other

"The 9th section of the 1st article declares that 'no preference shall be given, by any regulation of commerce or revenue, to the ports of one State over those of another' . . . But the subsequent part of the sentence is still more explicit. It is, 'nor shall vessels bound to or from one State be obliged to enter, clear, or pay duties, in another.' These words have a direct reference to navigation.'"

Case Citation:

Gibbons v. Ogden, 22 US 1 (1824)