## Facts

- Henry Fitzhugh, DeWitt C. Littlejohn, and James Peck owned the schooner *Cuba*, a vessel of fifty tons and upward, enrolled and licensed for the coasting trade and used in commerce between ports in different states on the Great Lakes and connecting waters.
- The *Cuba* was carrying 5,955 bushels of wheat on Lake Ontario, about forty miles below Niagara, on a voyage from Sandusky, Ohio to Oswego, New York.
- The steam propeller *Genesee Chief* (also of fifty tons and upward) was likewise enrolled and licensed for the coasting trade and engaged in similar interstate commercial service on the lakes.
- On May 6, 1847, the *Genesee Chief* collided with the *Cuba* on Lake Ontario; the schooner sank and the cargo was lost.
- The libel alleged the collision occurred through the carelessness and negligence of the master and crew of the *Genesee Chief*.
- The owners of the propeller admitted the collision and loss but contended the accident was caused by the carelessness, ignorance, mismanagement, and want of skill of the *Cuba*’s master and crew.
- The libellants filed a libel in admiralty in the U.S. District Court for the Northern District of New York, relying on the Act of Feb. 26, 1845 (5 Stat. 726), which extended federal admiralty jurisdiction to certain cases on the Great Lakes and the waters connecting them.
- The claimants objected to jurisdiction, arguing the collision occurred within New York’s territorial limits and not on the high seas or in tidal waters.
- The district court sustained jurisdiction and entered a decree for the schooner owners; the circuit court affirmed, and the owners of the propeller appealed to the Supreme Court.

## Issues

1. Whether the Act of Feb. 26, 1845, extending admiralty jurisdiction to cases on the Great Lakes and connecting waters, is consistent with Article III of the Constitution.
2. Whether constitutional “admiralty and maritime jurisdiction” is limited to waters affected by the ebb and flow of the tide, or instead extends to public navigable lakes and rivers used for interstate or foreign commerce.
3. Whether the collision was caused by fault of the steam propeller *Genesee Chief* or by fault of the sailing vessel *Cuba*.

## Decision

- The Supreme Court affirmed the decree for the owners of the schooner *Cuba*.
- The Court held the Act of Feb. 26, 1845 is constitutional because the Great Lakes and their connecting waters fall within the constitutional grant of admiralty and maritime jurisdiction.
- The Court rejected the tidewater limit and held that admiralty jurisdiction extends to all public navigable lakes and rivers where commerce is carried on between different states or with a foreign nation.
- On the merits, the Court held the steam propeller was at fault in the collision with the sailing vessel.

## Legal Principles

- “Admiralty and maritime jurisdiction” under Article III is not confined to tidewaters; it applies on public navigable lakes and rivers used for interstate or foreign commerce.
- Congress’s 1845 Great Lakes statute was valid because it operated within the constitutional category of admiralty jurisdiction, rather than creating a new head of federal judicial power.
- In a collision between a steam vessel and a sailing vessel, the steam vessel bears stringent duties of care; failure to keep a trustworthy lookout, properly stationed and vigilant, is prima facie evidence that the steam vessel was at fault.
- Prior statements that federal admiralty jurisdiction stopped at tidewaters (associated with earlier authority) were treated as mistaken in light of U.S. commercial conditions and the constitutional text.

## Conclusion

*The Propeller Genesee Chief v. Fitzhugh* held that federal admiralty jurisdiction is not tied to tidal waters and reaches the Great Lakes and other public navigable inland waters used for interstate or foreign commerce, sustaining the constitutionality of the 1845 Act; applying maritime collision rules, the Court affirmed decrees holding the *Genesee Chief* liable for sinking the *Cuba*, emphasizing the steam vessel’s duty to maintain a proper, vigilant lookout.


*The Propeller Genesee Chief v. Fitzhugh*, 53 U.S. (12 How.) 443 (1851)

The Propeller Genesee Chief v. Fitzhugh, 53 U.S. (12 How.) 443 (1851)