Jackson v. Steamboat Magnolia, USSC 1857: Admiralty Jurisdiction for All Navigable Waters
o Summary: The Supreme Court redefines the terms admiralty and maritime jurisdiction.
o Facts: Two vessels collided on the Mississippi river. One of the parties of the collision files a libel against the other party. However, the other party said that admiralty jurisdiction did not apply for two reasons because: 1) the accident happened in an area where the river was Non-Tidal and 2) the collision occurred within the bounds of a county. There was precedent for that because the early federal courts accepted these jurisdictional claims.
o Issue: What are the elements to establish jurisdiction?
o Holding: The Court eliminates elements of title and boundary of the county as criteria
for admiralty jurisdiction. Admiralty jurisdiction is now applied to all “navigable waters” of the US.
Reasoning: Force says that the use of the steamboat and the increase in river
transportation put pressure on the courts to extend admiralty jurisdiction. This case stands for the idea that Congress has the power to make maritime law. Article III is not merely an explanation of when congress has jurisdiction but allows the federal government to provide rights and remedies for maritime acts.
· Dissent (Daniels): Disagrees because he does not find the court’s reasoning in the plain language of the constitution.
· Dissent (McLean): the civil law encompasses all navigable waters. “Antiquity has its charms, as it is rarely found in the common walks of professional life; but it may be doubted whether wisdom is not more frequently found in experience and the gradual progress of human affairs; and this is especially the case in all systems of jurisprudence which are matured by the progress of human knowledge.”