St. John's Law Review

The Legal Meaning of “Commerce” in the Commerce Clause

By: Robert G. Natelson

This study examines the legal meaning of the word “commerce” in the Founding Generation in order to settle a long-standing controversy about the breadth of the Constitution’s Commerce Clause.

Traditionally, “commerce” in the Commerce Clause has been understood to encompass only buying, selling and associated activities.  Technically speaking, it is the Necessary and Proper Clause, not the Commerce Clause that the Supreme Court has employed to justify the expansion of the Commerce Power in modern times.  However, some scholars, argue that “commerce” was intended to have a much wider meaning—to include all economic transactions or even all economic and social transactions.  This view has become more important with recent scholarly findings that the Court’s reliance on the Necessary and Proper Clause is incorrect, because that Clause was designed to be only a rule of construction, not an independent source of power.

Prior studies of the Founding-Era meaning of “commerce” have focused on its meaning among lay persons.  However, the Constitution was universally understood to be a legal document, not a lay document.  Accordingly, this study examines the meaning of “commerce” in legal discourse.  For example, using an English database available at Oxford University, the author surveyed every appearance of “commerce” in English Reports, Full Reprint before 1800.  Based on this and other evidence, he concludes that among lawyers (1) the term “commerce” nearly always meant “mercantile activities,” and (2) that while it occasionally referred to sexual or social activities, it rarely, if ever, referred to the entire economy.