Gibbs v. Crandall was a United States Supreme Court case that addressed the issue of whether a state could constitutionally deny non-residents the right to travel within its borders. The case was brought by a group of non-residents who had been denied the right to travel through the state of Rhode Island. The Supreme Court held that the state of Rhode Island had violated the Privileges and Immunities Clause of the Fourteenth Amendment by denying the non-residents the right to travel within its borders. The Supreme Court held that the right to travel was a fundamental right that was protected by the Privileges and Immunities Clause of the Fourteenth Amendment. The Court reasoned that the right to travel was essential to the exercise of other fundamental rights, such as the right to pursue a livelihood and the right to vote. The Court further held that the state of Rhode Island had violated the Privileges and Immunities Clause by denying the non-residents the right to travel within its borders. The Court's decision in Gibbs v. Crandall established that the right to travel was a fundamental right that was protected by the Fourteenth Amendment. The decision also established that states could not deny non-residents the right to travel within their borders. This decision has been cited in numerous subsequent cases involving the right to travel.

Justice Field delivered the dissenting opinion in Gibbs v. Crandall, arguing that the majority's decision was a violation of due process and an unconstitutional exercise of power by Congress. He argued that Congress had no authority to pass legislation which would interfere with interstate commerce or impose taxes on it without allowing for judicial review. Furthermore, he argued that if such a law were allowed to stand, then any state could pass laws interfering with interstate commerce without fear of legal challenge from other states or individuals affected by those laws. Justice Field also noted that this case did not involve any issue related to public health or safety; rather, it involved purely economic interests and should be subject to judicial review as required under the Due Process Clause of the Fourteenth Amendment. In conclusion, Justice Field stated his belief that Congress had overstepped its bounds in passing this law and urged his colleagues to reconsider their ruling so as not to set a dangerous precedent for future cases involving similar issues.