Genesee Chief v. Fitzhugh

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12 How. (53 U.S.) 443 (1852), argued 2, 5, 6 Jan. 1852, decided 20 Feb. 1852 by vote of 8 to 1; Taney for the Court, Daniel in dissent. In Genesee Chief the Supreme Court expanded the scope of federal admiralty jurisdiction to encompass navigable fresh water lakes and rivers. The Supreme Court in an 1825 admiralty decision, The Thomas Jefferson, had adopted the traditional English rule restricting admiralty jurisdiction to tidal waters. Congress, however, desired to promote trade on interior waterways and enacted a statute in 1845 extending the jurisdiction of the federal courts to certain cases arising on the Great Lakes. The Supreme Court, in an opinion by Chief Justice Roger B. Taney, sustained the 1845 act and overruled its earlier decision. Taney emphasized that the English rule was unsuitable in the United States, with its network of navigable rivers and lakes. He concluded that admiralty jurisdiction depended upon “the navigable character of the water, and not upon the ebb and flow of the tide” (p. 457). In dissent, Justice Peter V. Daniel maintained that federal admiralty power was determined by the English practice at the time the Constitution was ratified.

The decision in Genesee Chief significantly encouraged commerce and navigation. By rejecting the tidal waters doctrine, the Supreme Court allowed Congress to regulate shipping on inland lakes and rivers by uniform admiralty principles. Moreover, the ruling exemplified the Court's willingness to accommodate legal doctrine to the emergence of new technology. The invention of the steamboat had revolutionized travel on inland waterways and rendered the tidal waters rule obsolete.

James W. Ely, Jr.

Subjects: Law.

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