Cooley v. Board of Wardens of the Port of Philadelphia
"Cooley v. Board of Wardens of the Port of Philadelphia" is a significant Supreme Court case that addresses the balance between state authority and federal regulation in the context of interstate commerce. The case arose when Aaron Cooley was fined for violating a Pennsylvania law that mandated ships entering or leaving Philadelphia to hire local pilots for navigation. Cooley challenged the law as unconstitutional, arguing that it imposed an undue regulation on interstate commerce. However, in a 6-2 ruling, the Supreme Court upheld the law, distinguishing between regulations that require a uniform national approach and those that are inherently local, such as pilotage. The decision established the "Cooley rule," which permitted states to maintain some level of control over specific activities related to commerce until Congress chose to intervene. This ruling has had a lasting impact on the interpretation of states' rights in relation to commerce and served as a practical framework for handling similar issues for nearly a century. The case illustrates the complexities of governance and the interplay between state and federal powers in the regulation of commerce.
Cooley v. Board of Wardens of the Port of Philadelphia
Date: March 2, 1852
Citation: 12 How. (53 U.S.) 299
Issue: Interstate commerce
Significance: In upholding a state statute regulating navigation standards for ships, the Supreme Court formulated the doctrine of selective exclusiveness, allowing states to regulate aspects of interstate commerce in the absence of federal laws.
A Pennsylvania law required each ship entering or leaving Philadelphia to hire a local pilot for navigation purposes. When Aaron Cooley was fined for disobeying the law, he argued that it was an unconstitutional regulation of interstate commerce. By a 6-2 vote, the Supreme Court rejected his argument. Speaking for the majority, Justice Benjamin R. Curtis made a distinction between activities needing a single national rule and other activities, such as pilotage laws, that were essentially local in nature. In the latter category, states retained a concurrent authority until Congress exerted its paramount power. The Cooley rule was essentially a compromise that allowed states to exercise limited control over interstate commerce, and it operated as a practical formula for nearly a century.
