The Daniel Ball – Case Brief Summary
Summary of The Daniel Ball, 77 U.S. (10 Wall.) 557, 19 L. Ed. 999 (1871).
Facts
The Daniel Ball was a steamer operating on the Grand River between Grand Rapids and Grand Haven, Michigan. A Congressional Act of 1838 made it unlawful to operate steam ships on the bays, lakes, rivers, or other navigable waters of the United States without a license. The Daniel Ball operated without the required license and was fined $500.
The United States government filed a libel against the ship to collect the amount of the fine. The owners of the ship asserted that the ship was not subject to the license requirement because the Grand River was not a navigable water of the United States and the ship did not engage in interstate commerce. The district court dismissed the libel action, the circuit court reversed on appeal, and the Supreme Court granted certiorari.
Issues
1) What constitutes a navigable water of the United States? 2) Does the Commerce Clause grant Congress the authority to regulate the transport of goods within a single state, if those goods are destined for or originated from another state?
Holding and Rule (Field)
1) A navigable water of the United States is one which forms, by itself or by uniting with other bodies of water, a continued highway over which commerce may be carried on with other states or foreign countries. 2) Yes. The Commerce Clause grants Congress the authority to regulate the intrastate transport of goods if those goods are destined for or originated from another state.
The mere transportation of goods within a state which are destined for interstate commerce is itself interstate commerce. It does not matter that several agencies are employed in transporting the goods, even if some of them do not cross state lines.
Disposition
Affirmed.
See United States v. Darby Lumber Co. for a constitutional law case brief in which the Supreme Court held that the Commerce Clause grants Congress the power to establish labor standards for the manufacture of goods for interstate commerce.