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In 1803, the State of Pennsylvania enacted a law that required ships entering or leaving the state’s ports to hire local pilots. Ship owners who refused to do so were required to pay a fee amounting to half the cost of hiring a local pilot to the Board of Wardens of the Port of Pennsylvania. Funds collected through the fee went to an aid society for elderly pilots, their widows, and orphans.
A ship owner named Aaron Cooley refused to hire a local pilot for his ships sailing from Philadelphia, and he wouldn’t pay the half-pilotage fee either. The Board of Wardens sued to collect the fee, and the case was ultimately taken up by the United States Supreme Court in Aaron B. Cooley v. The Board of Wardens of the Port of Philadelphia, 53 U.S. (12 How.) 299 (1851).
The issue before the Court was whether Pennsylvania had the power to regulate matters that related to interstate commerce. The Court ultimately upheld the law and affirmed the right of states to regulate local matters touching upon interstate commerce if the matter did not necessitate a uniform, national regulatory framework and if the state law did not conflict with any federal laws.
Cooley was a key case in the early evolution of Commerce Clause jurisprudence, as it established a subject-specific approach for courts to apply when considering the validity of state regulations as they relate to the Commerce Clause.