Question: The passage of the General Survey Act followed the landmark Supreme Court ruling, Gibbons v. Ogden, which was argued by what exiled Irish patriot?

Context paragraphs:
Same-sex marriage in the Sixth Circuit: On April 28, 2015, the Supreme Court of the United States heard oral arguments for "Obergefell v. Hodges" (Ohio), which was consolidated with three other same-sex marriage cases from the other states in the Sixth Circuit: "Tanco v. Haslam" (Tennessee), "DeBoer v. Snyder" (Michigan), "Bourke v. Beshear" (Kentucky).  On June 26, 2015 the Supreme Court reversed the Sixth Circuit's decision, paving the way for same-sex marriage to become legal in those states, and setting a precedent for the entire nation.  All four states complied with the ruling the same day it was issued before the mandate was actually issued.  Every state in the circuit had a district court ruling against their states' ban, but they were eventually stayed pending appeal.  The Sixth Circuit consists of Kentucky, Michigan, Ohio, and Tennessee.  On August 6, 2014, the Sixth Circuit heard oral arguments for same-sex marriage cases from each state within the circuit.  On November 6, 2014, the Sixth Circuit in a split 2-1 decision, upheld the states' same-sex marriage bans, reversing the district courts' rulings that struck them down.  The Sixth Circuit was the first and only circuit court since the landmark ruling "United States v. Windsor" to uphold the constitutionality of states' same-sex marriage bans which caused a circuit split.

California Education Code 48907: California Education Code 48907 (1977), also known as the California Student Free Expression Law, acts as a counter to the Hazelwood v. Kuhlmeier (1988) Supreme Court ruling, which limited the freedom of speech granted to public high school newspapers.  The Hazelwood v. Kuhlmeier decision held that public school curricular student newspapers that have not been established as "forums for student expression" are subject to a lower level of First Amendment protection than independent student expression or newspapers established (by policy or practice) as forums for student expression.  Ed Code 48907 affirms the right of high school newspapers to publish whatever they choose, so long as the content is not explicitly obscene, libelous, or slanderous.  The newspaper content must also pass the minimal disruption test set forth in the Supreme Court ruling on Tinker v. Des Moines (1969).  In contrast with Hazelwood, which limited First Amendment Protection to only those high school newspapers that had, through practice or policy, been established as forums for student expression, Ed Code 48907 affirms the right of all newspapers to the freedom of expression.

Commissioner v. Banks: Commissioner v. Banks, 543 U.S. 426 (2005), together with Commissioner v. Banaitis, was a case decided before the Supreme Court of the United States, dealing with the issue of whether the portion of a money judgment or settlement paid to a taxpayer's attorney under a contingent-fee agreement is income to the taxpayer for federal income tax purposes.  The Supreme Court held when a taxpayer's recovery constitutes income, the taxpayer's income includes the portion of the recovery paid to the attorney as a contingent fee.  Employment cases are an exception to this Supreme Court ruling because of the Civil Rights Tax Relief in the American Jobs Creation Act of 2004.  The Civil Rights Tax Relief amended Internal Revenue Service § 62(a) to permit taxpayers to subtract attorney’s fees from gross income in arriving at adjusted gross income.

Same-sex marriage in the Fourth Circuit: On July 28, 2014 the Fourth Circuit Court of Appeals upheld a ruling in "Bostic v. Schaefer" striking down Virginia's same-sex marriage ban which is a precedent for every state within the circuit.  The ruling would have gone into effect on August 21, 2014 but the Supreme Court of the United States granted the stay request by the clerk of Prince William County.  Attorneys for two same-sex couples had until August 18, 2014 to respond to the stay request.  The Fourth Circuit consists of Maryland, North Carolina, South Carolina, Virginia, and West Virginia.  Maryland was the first state in the circuit to enact gay marriage by legislative act and confirmed by a voter referendum.  That occurred prior to the Fourth Circuit Court ruling that was denied review at the Supreme Court, which led to the expansion to Virginia, West Virginia, and North Carolina.

Same-sex marriage in Missouri: Same-sex marriage in Missouri is legal under the U.S. Supreme Court's landmark ruling in "Obergefell v. Hodges", which struck down state bans on marriages between two people of the same sex on June 26, 2015.  Prior to the court ruling, the state recognized same-sex marriages from other jurisdictions pursuant to a state court ruling in October 2014, and certain jurisdictions of the state performed same-sex marriage despite a statewide ban.

Gibbons v. Ogden: Gibbons v. Ogden, 22 U.S. 1 (1824), was a landmark decision in which the Supreme Court of the United States held that the power to regulate interstate commerce, granted to Congress by the Commerce Clause of the United States Constitution, encompassed the power to regulate navigation.  The case was argued by some of America's most admired and capable attorneys at the time.  Exiled Irish patriot Thomas Addis Emmet and Thomas J. Oakley argued for Ogden, while U.S. Attorney General William Wirt and Daniel Webster argued for Gibbons.

Same-sex marriage in California: Same-sex marriage is legal in the U.S. state of California, and first became so on June 16, 2008, when the state began issuing marriage licenses to same-sex couples as the result of the Supreme Court of California ruling in "In re Marriage Cases", which found that barring same-sex couples from marriage violated the state's constitution.  The issuance of those licenses was halted during the period of November 5, 2008 through June 27, 2013 (though existing same-sex marriages continued to be valid) due to the passage of Proposition 8—a state constitutional amendment barring same-sex marriages.  The granting of same-sex marriages recommenced following the United States Supreme Court decision in "Hollingsworth v. Perry", which restored the effect of a federal district court ruling that overturned Proposition 8 as unconstitutional.

General Survey Act: The General Survey Act was a law passed by the United States Congress in April 1824, which authorized the president to have surveys made of routes for transport roads and canals "of national importance, in a commercial or military point of view, or necessary for the transportation of public mail."  While such infrastructure of national scope had been discussed and shown wanting for years, its passage shortly followed the landmark Supreme Court ruling, Gibbons v. Ogden, which first established federal authority over interstate commerce including navigation by river.  The president assigned responsibility for the surveys to the Corps of Engineers (USACE).

Cigna Healthcare of Texas, Inc. v. Calad: CIGNA v. Calad was a Supreme Court of the United States appeal and ruling, where CIGNA Healthcare, Inc. challenged a United States Court of Appeals for the Fifth Circuit ruling in favor of Mrs. Ruby Calad, who was insured under her husband's employer's self-funded medical insurance plan in the State of Texas.  This was a Landmark Supreme Court Case.

LGBT rights in Vermont: The establishment of LGBT rights in the US state of Vermont is a recent occurrence, with the majority of progress having taken place in the past century.  It was one of 37 US states, along with the District of Columbia, that issued marriage licenses to same-sex couples, until the landmark Supreme Court ruling of Obergefell v. Hodges that legalized equal marriage rights for same-sex couples nationwide.

Supporting paragraphs: General Survey Act Gibbons v. Ogden
Answer: Thomas Addis Emmet