Facts
- Frederick G. King suffered severe and permanent injuries when a boiler flue exploded aboard the steamboat New World during a voyage from Sacramento to San Francisco, California.
- King rode without paying fare under a widespread custom on Western steamboats allowing “steamboat men” (workers in the trade) to travel free of charge.
- Evidence indicated the New World and a rival vessel were attempting to outpace one another, and the New World’s engineer was closely monitoring the competing boat at the time of the accident.
- King filed a libel in admiralty in the U.S. District Court for the Northern District of California seeking damages for personal injury.
- The district court awarded King $2,500 in damages plus costs; the vessel’s owners appealed.
Issues
- Whether federal admiralty jurisdiction covered a personal-injury claim arising from a steamboat voyage between two ports within the same state on tidewaters used for commerce.
- Whether a person carried gratuitously under a general custom of free passage for “steamboat men” was a passenger to whom the vessel and owners owed a duty of care, and whether the master could bind the owners by granting such passage.
- What standard of care applied to steamboat carriers of persons, and whether a boiler/flue explosion constituted prima facie negligence shifting the burden to the owners to show absence of negligence.
Decision
- Admiralty jurisdiction was proper because the injury occurred on navigable tidewaters used for commerce.
- King was a passenger despite gratuitous carriage; the master had authority to grant free passage under a general, reasonable custom beneficial to owners, binding the vessel and owners to a duty of care.
- Steamboat carriers of persons owed the greatest possible care and diligence, whether the transportation was for compensation or gratuitous.
- Under the Act of July 7, 1838, an injurious escape of steam was prima facie evidence of negligence, placing the burden on the owners to prove the absence of negligence.
- The owners failed to rebut negligence on the evidence; the decree awarding $2,500 and costs was affirmed.
Legal Principles
- Federal admiralty jurisdiction extends to passenger personal-injury claims arising from navigation on tidewaters used for commercial navigation, even when the voyage is intrastate.
- A common carrier transporting persons by steam must exercise the greatest possible care and diligence for passenger safety, regardless of whether fare is paid.
- A master may bind vessel owners by granting free passage pursuant to a general, reasonable custom that is indirectly beneficial to the owners and not forbidden by them.
- Under the Act of July 7, 1838, an injurious escape of steam (including boiler or flue explosion) is prima facie negligence; owners must affirmatively prove due care to avoid liability.
- Failure to apply the skill and attention required to manage dangerous steam machinery supports a finding of gross negligence.
Conclusion
The Court held that a gratuitously carried “steamboat man” remained a protected passenger, that the steamboat owed the highest practicable care, and that a steam explosion created a statutory presumption of negligence the owners did not overcome; the damages award was affirmed.