## Facts

- Owners of the steamboat *Wetumpka* filed an admiralty libel seeking collision damages against the steamboat *Magnolia* and its master.
- The parties submitted the case on an agreed statement of facts limited to the threshold question of federal admiralty jurisdiction.
- *Wetumpka* was a federally enrolled and licensed coasting vessel (over thirty tons) engaged in commerce between New Orleans, Louisiana, and Montgomery, Alabama.
- *Magnolia* was a federally enrolled and licensed coasting vessel (over thirty tons) operating as a packet between Mobile, Alabama, and Montgomery, Alabama.
- The collision occurred on the Alabama River about 200 miles above tidewater, within Alabama.
- The district court dismissed the libel for lack of admiralty jurisdiction; the libellants appealed directly to the Supreme Court under the parties’ agreement.

## Issues

1. Whether federal admiralty jurisdiction extends to a collision between coasting vessels on a navigable river within a state when the collision occurs above the flux and reflux of the tide.
2. Whether jurisdiction over such a collision rests on the Judiciary Act of 1789 rather than the Act of 1845 (addressing the Great Lakes and waters not navigable from the sea).

## Decision

- The Supreme Court reversed the dismissal and held that federal admiralty jurisdiction covered the collision.
- The Court ruled that admiralty jurisdiction extends to collisions on navigable waters even when the location is within a state and above tidewater.
- The Court stated that district courts’ jurisdiction over fresh-water rivers “navigable from the sea” derives from the Judiciary Act of 1789, not the Act of 1845.
- The case was remanded for further proceedings on the merits consistent with the parties’ agreement.

## Legal Principles

- Federal admiralty jurisdiction includes civil collision claims arising on navigable waters of the United States, even if the collision occurs within a county and above the reach of the tide.
- For inland rivers that are “navigable from the sea,” admiralty jurisdiction exists under the Judiciary Act of 1789’s grant of exclusive original cognizance of admiralty and maritime causes.
- The Act of 1845 is an additional grant extending jurisdiction to the Great Lakes and waters not navigable from the sea; it does not limit preexisting admiralty jurisdiction over rivers navigable from the sea.

## Conclusion

The Court held that admiralty jurisdiction is not confined to tidewaters and reaches collisions on inland rivers that form navigable highways from the sea, reversing the district court’s jurisdictional dismissal and sending the case back for trial on the merits.


Jackson v. The Magnolia, 61 U.S. 296 (1858)