Case Facts: New York granted exclusive rights to steamboat navigation on New York state waters to Robert Livingston and Robert Fulton. Livingston then passed on that right to Ogden to navigate between New York City and New Jersey. Ogden then brought suit against Gibbons in order to keep him from operating steamboats on New York waters. The New York court granted the injunction, gibbons appealed claiming that his steam boats were licensed under an act of Congress which supersedes privileges given out by the State of New York. The chancellor affirmed the court’s decision. Gibbons appealed to the supreme court.
Issue/s: Can states grant exclusive rights to navigate waters within its borders?
Holdings/reasoning: No,
Under the constitution, Congress has the power to regulate commerce between the United States and foreign countries as well as among the states. Commerce encompasses more than traffic; it is intercourse which includes navigation. States cannot pass legislation for regulation of internal affairs, if the legislation is in conflict with federal law enacted under the Constitution. Any matter that affects interstate commerce is within the power of Congress.
Relevance: This case established Congress’s power to regulate interstate commerce under the Commerce clause. This decision stood until 1895, E.C. Knight Co. v. United States where the Supreme Court limited Congressional power to regulate under the commerce clause.
References:
Vile, John. R. 2014. Essential Supreme Court Decisions: Summaries of Leading Cases in U.S. Constitutional Law. Lanham, MD: Rowman and Littlefield.