Importance of The Case
Steven Redd argues that the decision in Gibbons v. Ogden survived until 1895, when the court began to limit the congressional power with the case of United States v. E. C. Knight Co., 156 U.S. 1 (1895). This marked the start of a 40-year period of history during which the Supreme Court limited the federal government's ability to regulate under the Interstate Commerce Clause. During the 1930s the Supreme Court changed course again and began to grant more federal authority under Commerce Clause, going beyond even the authority recognized in Gibbons v. Odgen. The Court went so far as to say that even activity entirely within one state could be regulated by the federal government if the activity had an effect on interstate commerce. See National Labor Relations Board v. Jones & Laughlin Steel Corporation, 301 US 1 (1937).
However, Strict Constructionists (those who believe that the Constitution must be given the narrowest possible construction) hold a different view of the meaning of Commerce Clause as established in Gibbons that it was limited in scope because the decision could be interpreted to say that navigation only pertained to the federal Commerce Clause because it was necessary to business as it allowed for the interstate transportation of goods. Therefore, under this theory the E.C Knight decision may be viewed not as a radical departure, but as a continuation of the original jurisprudence.
Note that in Gibbons v. Ogden the court specifically stated there are limits upon the federal commerce power, but chose not to put into detail what those limits were aside from goods specifically made, moved, and sold within one state were exclusively beyond the reach of the federal commerce power. This part of the Gibbons ruling stands in direct contrast to the post-New Deal decision in Wickard v. Filburn, 317 U.S. 111 (1942).
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