## Facts

- In September 1864, the steam tug *Eagle* towed a brig and a barge down the St. Clair and Detroit Rivers on a commercial trip from Saginaw, Michigan, to Buffalo, New York.
- While descending the Detroit River, the tug departed from the usual navigation route and crossed into shoal water near the international boundary.
- The brig grounded; the barge, still attached astern, struck the brig’s stern and caused serious damage.
- The brig’s owner filed an admiralty libel in federal district court in Michigan against the tug and the barge to recover collision damages.

## Issues

1. Whether federal admiralty jurisdiction extends to a maritime tort occurring on the Detroit River, a navigable water connecting the Great Lakes.
2. Whether the Act of 1845 extending district court jurisdiction over certain Great Lakes cases restricts admiralty jurisdiction to only the vessel classes and voyages described in that statute.

## Decision

- The Supreme Court affirmed the circuit court’s decree.
- The Court held that federal admiralty jurisdiction covered the collision on the Detroit River based on the Constitution and the general statutory grant of admiralty jurisdiction.
- The Court rejected the argument that the Act of 1845 limited admiralty jurisdiction on the Great Lakes and connecting waters to the statute’s specific terms.
- The decree holding the tug liable and exonerating the barge remained in place.

## Legal Principles

- Article III’s grant of admiralty and maritime jurisdiction reaches navigable waters used for commerce, including the Great Lakes and the waters connecting them, and is not confined to tidal waters.
- The Judiciary Act’s general conferral of admiralty jurisdiction is read in light of the constitutional grant and is not restricted by earlier, mistaken assumptions about tide-water limits.
- The Act of 1845 was an enlarging measure enacted under the then-prevailing but incorrect tide-water view; it does not diminish or define the outer boundary of constitutional admiralty jurisdiction.
- Federal admiralty jurisdiction may attach to torts on the Great Lakes’ connecting rivers even if an argument can be made that a particular segment of navigation lies within a single state.

## Conclusion

The Court sustained federal admiralty jurisdiction over a collision on the Detroit River and clarified that the 1845 Great Lakes statute does not narrow admiralty power that already exists under the Constitution and the general admiralty jurisdiction grant.


The Eagle, 75 U.S. (8 Wall.) 15 (1869)