## Facts

- New Jersey enacted an 1820 statute regulating oyster and clam harvesting in state waters, including seasonal limits and a restriction allowing harvesting only by New Jersey residents during the open season.
- Edward Corfield, a citizen of Pennsylvania, used his vessel, the sloop *Hiram*, to dredge for oysters in Maurice River Cove in Delaware Bay.
- New Jersey officers seized and sold the *Hiram* pursuant to the statute.
- Corfield sued the enforcing officials in an action of trespass in federal circuit court, seeking damages for the seizure and conversion of the vessel.

## Issues

1. Whether New Jersey’s resident-only oyster-harvesting restriction unconstitutionally regulated interstate commerce under the Commerce Clause.
2. Whether excluding nonresidents from harvesting oysters in New Jersey waters violated the Privileges and Immunities Clause of Article IV.
3. Whether enforcement through seizure in navigable waters intruded upon the federal judicial power over admiralty and maritime jurisdiction.

## Decision

- The circuit court (Washington, J.) upheld the New Jersey statute as constitutional.
- The court held the statute was a permissible state regulation of internal police and local resources, not an impermissible Commerce Clause regulation.
- The court held Article IV did not require New Jersey to extend to nonresidents the right to exploit oyster beds treated as common property of state citizens.
- The court rejected the claim that the seizure and enforcement were invalid because of exclusive federal admiralty jurisdiction.
- Judgment was for the defendants; the trespass claim failed because the seizure was justified under valid state law.

## Legal Principles

- State police power permits internal regulation within territorial limits that may indirectly affect commerce, so long as it does not conflict with federal regulation on the same subject.
- The Article IV Privileges and Immunities Clause protects only those privileges and immunities that are “fundamental” to citizens of free governments, not every benefit a state grants its own citizens.
- Examples of protected fundamental privileges include protection by government; enjoyment of life and liberty; the right to acquire, hold, and dispose of property; travel and residence for lawful pursuits; access to courts; habeas corpus; and protection against higher taxes than those imposed on in-state citizens.
- A state may treat certain natural resources within its territory as common property of its own citizens and may reserve their use to residents without violating Article IV.
- State regulation and enforcement relating to fisheries within state territorial limits do not necessarily fall within exclusive federal admiralty jurisdiction.

## Conclusion

The court sustained New Jersey’s resident-only oyster law and resulting vessel seizure, reasoning that the measure was a valid internal police regulation and that Article IV secures only fundamental privileges and immunities, not a nonresident right to exploit a state’s common natural resources.


Corfield v. Coryell, 6 F. Cas. 546 (C.C.E.D. Pa. 1823)