Gibbons v. Ogden
22 U.S. 1, 9 Wheat. 1 (1824)
Case Summary
A New York statute granted an exclusive right to certain individuals to use steam
navigation in all the waters of the state of New York for a period of 30 years, beginning
in 1808. Pursuant to this statutory license granting an exclusive privilege to the plaintiff
to operate steamboats in the waters of the state of New York, an injunction was issued
restraining defendant from navigating his steamboats in New York waters, which
defendant violated. In doing so, defendant contended that the plaintiff’s exclusive
privilege violated an act of Congress that specifically regulated the licensing of ships and
vessels in the coasting trade and fisheries. Thus, the defendant claimed that the New York
statute was contrary to the Constitution and laws of the United States. The New York
court found in favor of the plaintiff and upheld the original injunction against the
defendant. On appeal to the United States Supreme Court, the Court reversed, finding that
under the Commerce Clause, Congress’ authority to regulate commerce with foreign
nations or among the several states did not stop at individual state jurisdictional lines.
Instead, the Court explained that by attempting to regulate the defendant’s vessels in this
manner, the state of New York was exercising the very power that had been granted
exclusively to Congress relative to the navigation of the waters of the United States.
Thus, the Court declared the New York statute prohibiting non state-licensed vessels
from navigating the waters of the state to be void, as contrary to the Constitution.