Gibbons v. Ogden Case Brief

Facts of the case

A New York state law gave Robert R. Livingston and Robert Fulton a 20-year monopoly over navigation on waters within state jurisdiction. Aaron Ogden and other competitors tried to forestall the monopoly, but Livingston and Fulton largely succeeded in selling franchise or buying competitors’ boats. Thomas Gibbons — a steamboat owner who did business between New York and New Jersey under a federal coastal license – formed a partnership with Ogden, which fell apart after three years when Gibbons operated another steamboat on a New York route belonging to Ogden. Ogden filed suit against Gibbons in New York state court, and received a permanent injunction. The New York state court rejected Gibbons’ argument asserting that U.S. Congress controlled interstate commerce.

Why is the case important?

Ogden was given an exclusive license, pursuant to a New York statute, to run a ferry between New York and New Jersey. Gibbons obtained a license, pursuant to federal law, to run a ferry in New York waters, thus, running in interference with Ogden’s license. Ogden sought an injunction against Gibbons.

Question

Was the New York court’s injunction against Ogden’s license lawful?

ANSWER

No. The New York monopoly was invalid under the Supremacy Clause. Gibbons was given a license to move within the New York waterway, i.e., to navigate. Article I, Section 8 of the United States Constitution (Constitution) grants Congress the power to regulate commerce among the several states. Contrary to Ogden’s assertion, “commerce” means more than traffic. It also encompasses navigation. The phrase “among the several states” means “intermingled with them”. Therefore, Congress’ power to regulate “among the several states” must not stop at the external boundary line of each State. Congress’ power must also extend to each States’ interior. Moreover, the power of Congress to regulate within its proper sphere, e.g., interstate commerce, is exclusive.

CONCLUSION

The Court held that the act of Congress gave full authority to defendants’ vessels to navigate the waters of the United States. The law of the state of New York, prohibiting the vessels from navigating the waters of the state, was repugnant to the Constitution and void.

  • Advocates: Daniel Webster for Gibbons William Wirt Attorney General of the United States, for Gibbons Thomas Addis Emmet for Ogden Thomas J. Oakley for Ogden
  • Appellant: Thomas Gibbons
  • Appellee: Aaron Ogden
  • DECIDED BY:Marshall Court
  • Location: Ferry line between Elizabeth, New Jersey, and New York City
Citation: 22 US 1 (1824)
Argued: Feb 8, 1824 Feb 5, 1824 Feb 6, 1824 Feb 7, 1824 Feb 9, 1824
Decided: Mar 2, 1824
Gibbons v. Ogden Case Brief