Gibbons vs. Ogden and the Expansion of Federal Power

Background of Gibbons vs. Ogden

• Year: 1819
• Key Figure: Chief Justice John Marshall
• Court's Opinion: Expanded federal power by interpreting the Commerce Clause in Article 1 of the Constitution.
  • Commerce Clause: "Congress shall have power to regulate Commerce with foreign Nations, and among the several States, and with the Indian Tribes."

Importance of the Commerce Clause

• Historical Context: Under the Articles of Confederation, states taxed goods from other states, leading to conflicts.
• Purpose: To prevent states from taxing goods at the expense of other states and ensure that commerce among states was fair.

Case Details

• 1798: New York legislature grants Robert Livingston a monopoly to operate steamboats on the Hudson River.
• Partnership: Aaron Ogden and Thomas Gibbons operated steamboats between New York and New Jersey.
• Dispute: Ogden held monopoly under New York law, while Gibbons obtained a federal permit under the Coastal Licensing Act.
  • State Court Rulings: New York ruled in favor of Ogden.
  • Appeal to Supreme Court: Gibbons hired Daniel Webster, who argued for a broader interpretation of commerce.

Supreme Court's Decision

• Commerce Definition: Included navigation, as commerce was not limited to the buying and selling of goods.
• Outcome: Federal government could regulate any business crossing state lines.
• Impact: Expanded federal power significantly.

Broader Implications of the Decision

• Cartoon Explanation: Illustrates the conflict between state and federal regulation of commerce.
• Alternative Interpretation: The word "commerce" could have been limited to goods, restricting federal power.
• Expansion Examples:
  • 20th Century: Regulation of wheat production under the commerce clause.
  • Katzenbach Case (1964): Outlawed discrimination in public accommodations based on the commerce clause.
  • Obamacare: Although not upheld under the commerce clause, it illustrated the ongoing relevance and limits of federal power.

Legacy of John Marshall

• Three Key Cases:
  • Marbury vs. Madison: Established judicial review.
  • McCulloch vs. Maryland: Expanded federal power to include necessary and proper actions.
  • Gibbons vs. Ogden: Broadened federal influence through the commerce clause.