22 U.S. (9 Wheat.) 1, 6 L. Ed. 23 · Supreme Court of the United States · 1824
Constitutional LawAssigned in 25 casebooks
Case brief summary
Rule
The federal government controls trade and travel crossing state or national lines. If a valid federal law conflicts with a state law, the federal law wins. This power includes transportation, not just buying and selling.
Facts
New York gave two men exclusive rights to run steamboats there, later passed to Ogden. Gibbons ran competing boats between New Jersey and New York using a federal permit, so Ogden sued to stop him.
Procedural history
A New York court ordered Gibbons to stop operating his boats. New York's highest court upheld that order. Gibbons then appealed to the United States Supreme Court.
Issue
Does New York's law giving an exclusive right to run steamboats in its waters conflict with and have to give way to a federal law that licenses boats to carry goods and passengers along the coast, including between states?
Holding
The Supreme Court ruled New York's monopoly law invalid because it conflicted with the federal permit law. It reversed New York's decision and dismissed the case against Gibbons.
Reasoning
Commerce includes transportation, not just buying and selling. Federal power over interstate trade reaches into states when trade crosses state lines. Since Gibbons held a valid federal permit, the state law blocking him had to give way.
Opinions
Majority (Marshall): Federal commerce power covers navigation and interstate transport, so a conflicting state monopoly law must yield to a valid federal coasting license.
Concurrences (Johnson): Congress alone holds commerce power over interstate trade, making it exclusive, so states cannot regulate such commerce at all.
Test yourself
Question 1 of 5
What triggered the lawsuit between Gibbons and Ogden?
Ogden held an assignment of the Livingston-Fulton New York steamboat monopoly for the Elizabethtown-New York route, and sued to enjoin Gibbons, who operated competing federally licensed steamboats on that same route.
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On the exam
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Other issues in this opinion
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