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Keywords

jurisdictionregulationcommon law

common law

Related Cases

The Daniel Ball, 77 U.S. 557, 1870 WL 12737, 19 L.Ed. 999, 2000 A.M.C. 2106, 10 Wall. 557

Facts

In March 1868, the steamer Daniel Ball, a vessel of 123 tons burden, was navigating Grand River in Michigan, transporting merchandise and passengers between Grand Rapids and Grand Haven without the necessary federal inspection or license. The United States filed a libel in the District Court to recover penalties for this violation, asserting that Grand River was a navigable water of the United States. The owners of the steamer admitted to the employment of the vessel but contended that Grand River was not navigable and that their operations were solely within the state, thus exempt from federal regulation.

Issue

Whether the steamer was engaged in transporting merchandise and passengers on a navigable water of the United States and whether the federal acts apply to a steamer operating solely within the same state while transporting goods destined for other states.

Two questions are presented in this case for our determination. First: Whether the steamer was at the time designated in the libel engaged in transporting merchandise and passengers on a navigable water of the United States within the meaning of the acts of Congress; and, Second: Whether those acts are applicable to a steamer engaged as a common carrier between places in the same State, when a portion of the merchandise transported by her is destined to places in other States, or comes from places without the State, she not running in connection with or in continuation of any line of steamers or other vessels, or any railway line leading to or from another State.

Rule

The test for navigability in the United States is based on the river's capacity to be used as a highway for commerce, rather than the common law doctrine of navigability based on tidal influence. Rivers are considered navigable if they can be used for trade and travel in their ordinary condition.

The doctrine of the common law as to the navigability of waters has no application in this country. Here the ebb and flow of the tide do not constitute the usual test, as in England, or any test at all of the navigability of waters. The test by which to determine the navigability of our rivers is found in their navigable capacity. Those rivers are public navigable rivers in law which are navigable in fact.

Analysis

The court determined that Grand River was indeed a navigable water of the United States, as it could support a steamer of significant burden and formed a continuous highway for commerce with other states. The court rejected the argument that the steamer's operations were purely domestic, emphasizing that the transportation of goods destined for other states constituted interstate commerce, thus falling under federal jurisdiction.

If we apply this test to Grand River, the conclusion follows that it must be regarded as a navigable water of the United States. From the conceded facts in the case the stream is capable of bearing a steamer of one hundred and twenty-three tons burden, laden with merchandise and passengers, as far as Grand Rapids, a distance of forty miles from its mouth in Lake Michigan. And by its junction with the lake it forms a continued highway for commerce, both with other States and with foreign countries, and is thus brought under the direct control of Congress in the exercise of its commercial power.

Conclusion

The court affirmed the decision of the Circuit Court, ruling that the steamer Daniel Ball was subject to federal regulations and penalties for operating without the required inspection and license.

We perceive no error in the record, and the decree of the Circuit Court must be AFFIRMED.

Who won?

United States, as the court ruled that the steamer was engaged in interstate commerce and thus subject to federal regulation.

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