Gibbons v. Odgen, 22 U.S. 1 (1824) is a landmark decision in which the Supreme Court of the United States held that the power to regulate interstate commerce, granted to Congress by the Commerce Clause of the United States Constitution, encompassed the power to regulate interstate navigation. Abraham Van Vechten played a significant role in this famous case, which established the exclusive power of Congress to regulate interstate commerce. New York had granted a franchise to two of its own residents to operate steamboats on New York waterways, including Aaron Ogden, a former Governor of New Jersey. The New York Courts upheld the franchise and excluded other out of state competitors, such as Thomas Gibbons. Thomas Gibbons was represented by Abraham Van Vecthten. The case went to the United States Supreme Court. Daniel Webster argued the case for Gibbons before the Supreme Court, based on Van Vecthten’s argument that States’ restraints on commerce was unconstitutional. The Supreme Court adopted Van Vecthten’s argument and held that New York’s restrictive law was unconstitutional and that the State lacked the power to exclude Gibbons from operating his vessels on New York waterways. Click here for decision.
People v. Godfrey, 17 Johns. 225 (1819) is a landmark case that is referenced in The Founder’s Constitution, an anthology of writings (letters, records of debates and early cases) relating to the Federal Constitution as Document 17 of the materials underlying Article 1, Section 8, Clause 17 (Jurisdiction).
On August 25, 1818, William Godfrey, a soldier stationed at Fort Niagara, was on duty as an orderly sergeant. He was given an order to place a fellow soldier, Thomas Branaghan, in a place of punishment known as the Black Hole. Branaghan resisted Godfrey’s efforts to confine him, and when finally imprisoned, remonstrated with Godfrey using “bitter epithets.” Godfrey became enraged and struck out at Branaghan with a backhanded thrust of his musket. The musket’s bayonet wounded Branaghan who shortly afterwards died from his injuries.
Godfrey was brought to trial at the Niagara County Court of Oyer and Terminer. Immediately, he challenged the jurisdiction of the court, asserting that because the injury that caused Branaghan’s death had occurred within a fort of the United States Government, only the federal courts had power to hear the case. Although Justice Platt allowed the trial to continue and Godfrey was found guilty, he deferred Godfrey’s sentencing until the jurisdictional issue had been decided by the New York Supreme Court of Judicature.
In the Supreme Court, Attorney General Oakley represented the People while Godfrey was represented by Daniel Cady. The arguments focused on the history of the fort at Niagara which had originally belonged to France, was captured by the British in 1759, and was transferred from France to Britain under the 1763 Treaty of Paris. Following the Revolutionary War, the right of the British Crown to the territory comprising the State of New York became vested in the People of New York, in full sovereignty. The Treaty of 1783 recognized the boundaries of New York State, and the Articles of Confederation expressly reserved the sovereignty of each State. The fort itself was surrendered to the United States under the Treaty of 1794 and since that time it had been possessed and garrisoned by the United States. The Supreme Court held that the fort was subject to the jurisdiction of the State since the lands upon which it stood had not been ceded to the United States. Chief Justice Spencer wrote the opinion of the Court in which he stated that it was beyond all doubt that the United States acquired no territorial rights to any portion of the State of New York under the treaties of 1783 and 1794.
When Great Britain withdrew its garrisons, the forts became the property of the several States within whose limits the garrisons were located. The occupation of the fort by United States troops since its evacuation by the British under the treaties could neither be considered as evidence of the right of the federal government to the post itself nor an act hostile to the rights of the State of New York. The Court was “perfectly satisfied that the jurisdiction of this state attaches on the crime, and extends to the person of the prisoner, and nothing remains but that judgment be passed upon him according to law.”
People v. Van Rensselaer, 9 N.Y. 291 (1853) & People v. Clarke, 9 N.Y. 349 (1853) involved the long simmering issue of manorial titles came to the fore again in the mid-19th century Anti-Rent Wars and, in 1848, Governor Young and the Legislature authorized the Attorney General to bring court actions on behalf of the State challenging the manorial land titles.
People v. Van Rensselaer came before the Supreme Court, Rensselaer County, on January 23, 1851, and the parties waived a jury trial. Justice Ira Harris granted judgment for the People for the recovery of possession of the land and this judgment was affirmed general term. The defendant, William P. Van Rensselaer, then appealed to the New York Court of Appeals.
Charles M. Jenkins represented Van Rensselaer at the Court of Appeals and argued that the Supreme Court erred in holding: “That the provisions of both patents, that of 1685 and that of 1704, whereby manorial privileges and franchises were conferred upon the lord of the manor, were in express violation of the established law, not only in England, but of this colony, and for this reason both grants were illegal and void.”
Levi S. Chatfield, the Attorney General, represented the respondents, the People of the State of New York. He asserted that the title of the People “rests in their right of sovereignty” and that the People are deemed to possess the original and ultimate property in and to all lands within the jurisdiction of the state (Constitution, § 11, art. 1).
The Court of Appeals held, in an opinion written Judge John Willard, that: “The conclusion to which I have come, that the patents were both valid, and were effectual to divest the colonial government of all title to the land in dispute, is enough to dispose of the case upon its merits. I think, too, a regular paper title has been deduced from the original patentee to the present owners, and that their title is good against all the world.”
The ground of this decision was that, whatever may have been the imperfections of the original title, the act passed in 1830 limiting the impeachment of titles by the State to a period within forty years preclude any questioning of the title.
Although Judge Denio wrote separately, the Court of Appeals unanimously held that the judgments of the Supreme Court and Circuit Court should both be reversed, and a new trial ordered with costs to abide the event.
In People v. Clarke, Attorney General Levi S. Chatfield sought invalidation of a patent, dated November 19, 1737 in the reign of George II, under the great seal of the province of New York and signed by George Clarke, lieutenant-governor, for 25,400 acres of land in Albany County, southward of the Mohawk River and westward of Schoharie River, to William Corry and twelve other persons. The Attorney General alleged that Clarke himself was the real grantee, and that he made use of his position as a member of the council to obtain this valuable property for himself. The case was heard at a special term in Montgomery County in December, 1850 before Justice Daniel Cady, who ordered judgment for the defendant Clarke, and this judgment was affirmed by the General Term of the Fourth District (11 Barb. 337). The People of the State of New York, represented by Attorney General Levi S. Chatfield, appealed to the New York Court of Appeals, which affirmed the decision of the lower court on the same ground as the decision that had been reversed in the Van Rensselaer case-the act passed in 1830 limiting the impeachment of titles by the State to a period within forty years.
As Judge Francis Bergan wrote in his seminal work on the New York Court of Appeals: “Thus the great controversy of New York’s anti-rent wars wound down to a judgment for the patroon in the court that came into being on the wind of that controversy.”