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Keywords

injunctionappealregulation
plaintiffinjunctionregulationappellant

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Gibbons v. Ogden, 22 U.S. 1, 1824 WL 2697, 6 L.Ed. 23, 9 Wheat. 1

Facts

Aaron Ogden filed a bill in the Court of Chancery of New York against Thomas Gibbons, claiming that Gibbons was violating New York laws that granted exclusive navigation rights to Livingston and Fulton. Ogden had acquired the rights through an assignment and sought an injunction to prevent Gibbons from operating his licensed steam boats in the waters between New Jersey and New York. The Chancellor upheld the injunction, leading to an appeal to the Supreme Court.

The bill stated an assignment from Livingston and Fulton to one John R. Livingston, and from him to the complainant, Ogden, of the right to navigate the waters between Elizabethtown, and other places in New-Jersey, and the city of New-York…

Issue

Did the New York state law granting exclusive navigation rights to Livingston and Fulton conflict with the federal government's power to regulate interstate commerce?

Are these laws such as the Legislature of New-York had a right to pass? If so, do they, secondly, in their operation, interfere with any right enjoyed under the constitution and laws of the United States, and are they, therefore, void, as far as such interference extends?

Rule

The power to regulate commerce is exclusively vested in Congress, and state laws that conflict with federal regulations are void. This includes the regulation of navigation and commerce between states.

The power of regulating commerce extends to the regulation of navigation… The power to regulate commerce is general, and has no limitations but such as are prescribed in the constitution itself.

Analysis

The Supreme Court found that the New York law conflicted with the federal licensing system established under Congress. The Court emphasized that the regulation of interstate commerce, including navigation, is a power that cannot be exercised by the states if it interferes with federal authority. The Court ruled that the federal license held by Gibbons allowed him to operate his steam boats in New York waters, despite the state law.

The laws of N. Y. granting to R.R.L. and R. F. the exclusive right of navigating the waters of that State with steam boats, are in collision with the acts of Congress regulating the coasting trade, which being made in pursuance of the constitution, are supreme, and the State laws must yield to that supremacy…

Conclusion

The Supreme Court reversed the decision of the New York courts, ruling that the state law was unconstitutional and that Gibbons had the right to operate his steam boats in the waters of New York.

The Chancellor perpetuated the injunction, being of the opinion, that the said acts were not repugnant to the constitution and laws of the United States, and were valid.

Who won?

Thomas Gibbons prevailed in the case because the Supreme Court determined that the New York law was unconstitutional and that federal law took precedence over state law in regulating interstate commerce.

The appellant being owner of a steam-boat, and being found navigating the waters between New-Jersey and the city of New-York, over which waters Ogden, the plaintiff below, claimed an exclusive right, under Livingston and Fulton, this bill was filed against him by Ogden…

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