Note 328 — ARTICLE I (continued 2)

Gibbons v. Ogden, 9 Wheat. 1, 196. Commerce "among the several States" does not comprise commerce of the District of Columbia nor the territories of the United States. Congress's power over their commerce is an incident of its general power over them. Stoutenburgh v. Hennick, 129 U.S. 141 (1889); Atlantic Cleaners and Dyers, Inc. v. United States, 286 U.S. 427 (1932); In re Bryant, 4 Fed. Cas. No. 2067 (1865). Transportation between two points in the same State, when a large part of the route is a loop outside the State, is "commerce among the several States." Hanley v. Kansas City Southern R. Co., 187 U.S. 617 (1903); followed in Western Union Telegraph Co. v. Speight, 254 U.S. 17 (1920), as to a message sent from one point to another in North Carolina via a point in Virginia.