Facts
- New York statutes granted Livingston and Fulton exclusive rights to operate steamboats in New York waters; those rights were assigned to others, including Aaron Ogden.
- Ogden held an assigned right to run steamboats between Elizabethtown, New Jersey, and New York City under the New York monopoly.
- Thomas Gibbons operated competing steamboats on the same route.
- Gibbons’ vessels were federally enrolled and held coasting licenses under an Act of Congress regulating the coastal trade.
- Ogden sought to stop Gibbons from operating in New York waters, asserting violation of the state-granted exclusive franchise.
- Gibbons contended that his federal licenses authorized the route and displaced the state monopoly.
Issues
- Whether “commerce” in Article I, § 8, cl. 3 includes navigation.
- Whether commerce “among the several States” reaches interstate commercial intercourse that includes travel within a state’s waters.
- Whether New York’s steamboat monopoly is invalid to the extent it conflicts with federal regulation of the coasting trade.
- Whether a federal coasting license authorizes navigation in interstate commerce notwithstanding a contrary state-created exclusive franchise.
Decision
- The Supreme Court reversed the state court judgment and dissolved the injunction against Gibbons.
- The Court held that “commerce” includes commercial intercourse and therefore includes navigation.
- The Court held that commerce “among the several States” covers commerce concerning more than one state and does not stop at state boundary lines.
- The Court held that federal coasting-trade licensing enacted under the Commerce Clause is supreme, and conflicting state laws must give way.
- The New York monopoly was unconstitutional as applied to bar federally licensed vessels engaged in interstate navigation.
Legal Principles
- Congress’s power to regulate interstate commerce extends to the regulation of navigation when connected to commerce with other states or nations.
- Commerce “among the several States” includes interstate channels and instrumentalities even when activity occurs within a single state as part of interstate intercourse.
- When Congress validly legislates under the Commerce Clause, the Supremacy Clause requires conflicting state laws to yield.
- A federal coasting license is an affirmative authorization to participate in the coasting trade; a state may not prohibit what federal law permits in interstate commerce.
- The commerce power applies to transportation of passengers and to vessels propelled by steam as well as by sail.
- Commerce that is completely internal to a state and does not affect other states remains outside the federal commerce power.
Conclusion
The Court invalidated New York’s steamboat monopoly to the extent it interfered with federally licensed interstate navigation, establishing that the Commerce Clause reaches navigation as part of interstate commercial intercourse and that federal regulation preempts contrary state restrictions.