Gibbons v. Ogden (1824) was a Supreme Court case that famously expounded upon the powers of the commerce clause, setting the precedent of Congress’s broad ability to regulate interstate and some intrastate commerce. The case originated in a dispute over shipping monopolies in New York. Ogden and Gibbons both were in the business of steamboat operations between New York and New Jersey. Ogden had a monopoly from the state of New York over steamboat operations in state waters, but Gibbons had a federal license to operate within New York. After a New York court granted an injunction against Gibbons, Gibbons appealed up to the Supreme Court which found that Congress had the ability to regulate the shipping under the commerce clause and therefore superior to the state’s regulations. The case involved many historical figures of business and law including Cornelius Vanderbilt and Daniel Webster. The court decided in this case that the commerce clause allows Congress to regulate not only interstate commerce but also intrastate commerce (commerce within a state) that substantially impacts interstate commerce. This decision in Gibbons v. Ogden set the foundation for later cases such as Wickard v. Filburn that greatly expanded the ability of Congress to regulate commerce within a state itself. [Last updated in January of 2022 by the Wex Definitions Team]  Gibbons v. Ogden is a 1824 landmark case of the Supreme Court of the United States, which gave Congress complete power in regulating interstate commerce. The case questioned whether or not the State of New York could regulate interstate commerce - typically Congress’ right. In a unanimous decision that referenced the Supremacy Clause, the Supreme Court found in favor of Gibbons.[1] BackgroundAfter Robert Livingston and Robert Fulton invented the fastest steamboat, the State of New York granted them a thirty year monopoly for navigating those waters by steamboat. With their monopoly, they granted other individuals the right to navigate these waters as well. One of these men was Aaron Ogden, who was permitted to navigate from New Jersey to New York. Ogden’s competitor, Thomas Gibbons, already held a federally granted license to operate those waters. Ogden filed suit against Gibbons in the courts of New York, where they ruled in favor of Ogden. As a result, Gibbons appealed to the Supreme Court of the United States. The case was originally brought to court as a patent case. Livingston and Fulton did not permit Gibbons to navigate these waters, so Ogden rightly assumed that he could bring an infringement suit against him. What would become the central conflict in the case, however, was whether or not the State of New York had the right to grant the monopoly on interstate waterways.[2] Stakeholders
Rulings
Supreme CourtSupreme Court of the United States – March 2, 1824 There were two main questions addressed in the March 1824 ruling: Did the State of New York law violate Congress' authority regulate commerce? Was New York State law inconsistent with Congress patent law? Decision: All six justices voted unanimously in favor of Gibbons: John Marshall, Bushrod Washington, William Johnson, Jr., Thomas Todd, Gabriel Duvall and Joseph Story. Despite being argued on patent law, the case was ruled according to the Commerce Clause. Marshall wrote because Gibbons held a federal coasting license, he was permitted to sail any of the waters of the United States. Furthermore, federal law invalidated the state law. Marshall did not address the patent issue at all, saying that it was not necessary.[2]
New York Supreme CourtThe decision of the Court of Chancery was upheld by the court of last resort in the State of New York.[4] Court of ChanceryAaron Ogden filed a complaint asking the courts to stop Thomas Gibbons from operating boats for commercial use from New Jersey to New York.[5]
In 1819, the New York Court of Chancery ruled that Aaron Ogden has the right to operate exclusively in the waters between New York and New Jersey.[5] LegacyThis ruling, early in the history of the United States, asserted Congress' authority to regulate interstate commerce on the basis of the Supremacy Clause. It set a precedent that Congress had the power to overturn state regulations if interstate commerce were involved. For example, if a factory participated in interstate commerce, Congress not only had the power to regulate how the goods were sold, but they also had the power to regulate what happened in the factory, like the payment of minimum wage. The ruling allowed for the spread of the federal government’s powers.[4] According to SCOTUSblog, "the Constitution expressly confers on Congress the authority to regulate commerce among the several states," and the Supreme Court said in the ruling that the commerce power of Congress "is complete in itself, may be exercised to its utmost extent, and acknowledges no limitations, other than are prescribed in the constitution."[6] Though the power of Congress was extensive, some restrictions were found to apply to this ruling. In later years, it was specified that commerce had to occur between two or more states. According to the Cato Institute, the ruling did not stretch to include foreign commerce, trade with Indian nations, manufacturing, or the regulation of child labor.[2]
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How did the Scotus ruling in Gibbons v. Ogden increase the power of the federal government?
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