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The Steam-Boat Thomas Jefferson

Is it still good law? What later courts have actually done to this case.

Overruled
Court
Supreme Court of the United States
Citation
23 U.S. 428
Decided
Confirmed treatments
2
Flagged citations read
16 of 16
Treatment dates
1852–1903
Overruled
A reviewed court has overruled this case. The Steam-Boat Thomas Jefferson was overruled: all 16 flagged citations have been read, and two confirmed treatments are listed below. In The Propeller Genesee Chief v. Fitzhugh, the Supreme Court rejected Thomas Jefferson's rule limiting admiralty jurisdiction to tidewater.
More on how this was screened

The Robert W. Parsons later criticized its sparse explanation of that rule.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

16 citations to The Steam-Boat Thomas Jefferson sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

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Treatments

Overruled

  • The Supreme Court rejected Thomas Jefferson's tidewater limit and held that admiralty jurisdiction reaches public navigable waters without a tide.

    The Propeller Genesee Chief v. Fitzhugh · Supreme Court of the United States · filed

    It is the decision in the case of the Thomas Jefferson which mainly embarrasses the court in the present inquiry. ... And as we. are convinced that the former decision was founded in error, and that the error, if not corrected, .must produce serious public as well as private inconvenience and loss, it becomes our duty not to perpetuate it.
    Read the full opinion on CourtListener →

Criticized

  • The Supreme Court criticized Thomas Jefferson's thin explanation of the tidewater rule.

    The Robert W. Parsons · Supreme Court of the United States · filed

    At an early day; and following English precedents, it was held by this court in The Thomas Jefferson, 10 Wheat. 428, that the admiralty courts could not rightfully exercise jurisdiction “except in cases where the service w;as substantially performed, or to be performed, upon the sea, or upon waters within the ebb and flow of the tide.” The opinion is a brief one by Mr. Justice Story, and contains little more than the announcement of the general principle, and with no attempt to distinguish the English cases. It lacks wholly any display of the abundant learning which ten years before had characterized his celebrated opinion in De Lovio v. Boit, 2 Gall. 398; S. C., Fed. Cas. No. 3776.
    Read the full opinion on CourtListener →

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