Summarize this.
Many states in the early 1800s passed laws to protect businesses within their borders. New York gave two men the exclusive right of steamboat navigation on the state's waters. One of the men was Robert Fulton, who invented the steamboat Clermont. Aaron Ogden had a special license from the men to use steamboats on the state's waters. Ogden requested that a local court stop Thomas Gibbons from running his boats, which competed with Ogden's. The court agreed and issued Gibbons an injunction to stop using his boats in New York.
Gibbons appealed the decision to the U.S. Supreme Court. He had permission from Congress to use his steamboats between New Jersey and New York waters. Business that involves more than one state is interstate trade. Congress regulated interstate commerce under the U.S. Constitution. Chief Justice John Marshall presided over the case.
Did Congress have the power to override state laws related to commerce?
Gibbons Argument:
Under the Commerce Clause (Article I, Clause 8), Congress has the right to regulate interstate trade. Transportation over water is an essential part of that trade. Congress has a law regulating coastal trade. Therefore, a state law that interferes with navigation relating to interstate trade conflicts with the Commerce Clause.
Ogden Argument:
The Commerce Clause refers to interstate trade only. The New York law applies only within the borders of New York. New York has rights under the Constitution to make laws to protect its interests within its borders.
Was the New York law that granted exclusive navigation unconstitutional, interfering with federal powers?
Gibbons Argument:
The Supremacy Clause (Article VI, Clause 2) states that federal law takes priority over state law. The Commerce Clause includes any activity that affects interstate commerce, including navigation. The New York law prevents navigation of out-of-state traders on its waters. If New York can grant exclusive rights of navigation, it will prevent the flow of trade between states along the coast.
Ogden Argument:
New York is a sovereign state; it has the right to regulate businesses in its state borders, including the granting of special rights of navigation. Commerce is the trade in goods and services. It does not include movement of goods over state water. Navigation is not part of the Commerce Clause, and therefore the states have the right to regulate it.
The Judgment
The Supreme Court unanimously (6–0) ruled in favor of Gibbons and the federal government. The case was important because it established a precedent for the Congress to override a state law when it conflicts with a federal law. It also extended the definition of commerce to include navigation. States could not pass commerce laws in direct conflict with federal law. The case has an economic impact as well, because the decision allows the federal government some control over trade within and across state borders.