During early 1941, with war raging in Europe, Franklin D. Roosevelt pushed to have<span> the United States' factories become an "arsenal of democracy</span>
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<span>This was the Gibbons v. Ogden ruling. In this case, Marshall held that the Interstate Commerce clause was able to be used to regulate commerce in the case of a steamboat operator who wanted to work the waterways connecting New York and New Jersey.</span>
