1052 Gilman, 70 U.S. at 724; accord Gibbons, 22 U.S. at 190 (“All America understands, and has uniformly understood, the word ‘commerce,’ to comprehend navigation. It was so understood, and must have been so understood, when the constitution was framed. The power over commerce, including navigation, was one of the primary objects for which the people of America adopted their government, and must have been contemplated in forming it.”); see United States v. Appalachian Elec. Power Co., 311 U.S. 377, 426-27 (1940).1053 Rands, 389 U.S. at 123; accord Cherokee Nation, 480 U.S. at 704.