Osborn v. Bank of the United States

Wed, 10 Mar 1824 13:00:00 +0000

Case Basics

Petitioner

Osborn

Petitioner Type

Petitioner

Respondent

Bank of the United States

Respondent Type

Respondent

Heard By

Marshall Court (1824-1826)

Decided By

Marshall Court (1824-1826)

Opinion

22 U.S. 738 (1824)

Argued

Wednesday, March 10, 1824

Decided

Friday, March 19, 1824

Facts of the Case

The state of Ohio levied taxes on each branch of the United States Bank in Ohio. Although the Court ruled in McCulloch v. Maryland that such taxes were unconstitutional, Ohio persisted in its enforcement of the tax. Defying a circuit court injunction, Ralph Osborn, the Ohio State Auditor, forcibly seized funds from the Bank. The circuit court then ordered Osborn and his colleagues to repay the amount seized.

Question

Did the federal circuit court's assertion of jurisdiction over the case, which involved an action commenced against the state of Ohio, violate the Eleventh Amendment?

Conclusion

In a 6-to-1 decision, the Court held that the circuit court properly ruled against Ohio officials and that the Ohio law was "repugnant to the Constitution." The Court held that the Eleventh Amendment was limited to suits in which a state was party on the record, and that Ohio was not the target of the suit in the case at hand. Osborn and his colleagues were thus "incontestably liable for the full amount of the money taken out of the bank."

Gibbons v. Ogden

Wed, 04 Feb 1824 13:00:00 +0000

Location

New York State Capitol

Washington Avenue and State Street Albany NY 12224

Albany, NY 12224

United States

42° 39' 0.4392" N, 73° 45' 35.5248" W

See map: Google Maps

Case Basics

Petitioner

Gibbons

Petitioner Type

Petitioner

Respondent

Ogden

Respondent Type

Respondent

Heard By

Marshall Court (1823-1824)

Decided By

Marshall Court (1824-1826)

Opinion

22 U.S. 1 (1824)

Argued

Wednesday, February 4, 1824

Decided

Tuesday, March 2, 1824

Facts of the Case

A New York state law gave two individuals the exclusive right to operate steamboats on waters within state jurisdiction. Laws like this one were duplicated elsewhere which led to friction as some states would require foreign (out-of-state) boats to pay substantial fees for navigation privileges. In this case a steamboat owner who did business between New York and New Jersey challenged the monopoly that New York had granted, which forced him to obtain a special operating permit from the state to navigate on its waters.

Question

Did the State of New York exercise authority in a realm reserved exclusively to Congress, namely, the regulation of interstate commerce?

Conclusion

Decision: 6 votes for Gibbons, 0 vote(s) against
Legal provision: US Const. Art 1, Section 8, Clause 3; Act of February 1793, Section 1, Clause 8

The Court found that New York's licensing requirement for out-of-state operators was inconsistent with a congressional act regulating the coasting trade. The New York law was invalid by virtue of the Supremacy Clause. In his opinion, Chief Justice Marshall developed a clear definition of the word commerce, which included navigation on interstate waterways. He also gave meaning to the phrase "among the several states" in the Commerce Clause. Marshall's was one of the earliest and most influential opinions concerning this important clause. He concluded that regulation of navigation by steamboat operators and others for purposes of conducting interstate commerce was a power reserved to and exercised by the Congress.

Cases - 1824 term

Osborn v. Bank of the United States

Gibbons v. Ogden

Location