Cites Geismer v. Lake Shore & Michigan Southern Railway Co. — Weed v. P. B. B. Go. (17 N. T. 362), Blaekstoek v. N. T. & B. B. B. Go. (1 Bosw. 77; affirmed, 20 N. T. 48), distinguished, Geismer v. L. 8. & M. 8. B. R. Go. (34 Hun, 50), reversed.
Affiliations
Supreme Court of the United States — appointed by Chester Arthur
This case involved a claim to land originally granted by Spanish authorities in 1768, which had later been included in congressional grants confirmed by acts in 1860 and 1869 with patents issued by the United States. The Court of Private Land Claims determined it lacked jurisdiction to confirm the claim because of the prior congressional action but nonetheless declared that a complete title had vested under the Spanish grant. The Supreme Court ruled that the lower court had no authority to address the merits of the claim, as the statute creating the Court of Private Land Claims expressly prohibited it from considering lands whose rights Congress had already decided. The decree was therefore reversed with directions to dismiss the petition for lack of jurisdiction.
This case involved a challenge to a Massachusetts statute making it unlawful for any insurance agent or broker to negotiate or transact insurance on property in the state with a foreign insurance company not admitted to do business there. The defendant was convicted for soliciting a marine insurance policy from Lloyds of London on behalf of a Boston vessel owner and facilitating its delivery. The Supreme Court upheld the conviction and the constitutionality of the statute, holding that states possess broad power to condition or prohibit the business of foreign insurance companies and their agents or brokers within state borders. The Court reasoned that contracts of marine insurance are not instruments of interstate commerce but mere incidents of it, distinguishing the facts from Allgeyer v. Louisiana while following Hooper v. California.
The case concerned whether a party could appeal a decision of the Supreme Court of the Territory of Hawaii in an admiralty case to the United States Circuit Court of Appeals for the Ninth Circuit. The underlying dispute involved a libel in admiralty that had been pending in the courts of the Republic of Hawaii at the time Congress enacted the 1900 territorial government act, which directed that such pending proceedings continue to final judgment in the corresponding territorial courts. The Supreme Court held that the appeal was properly disallowed because the 1900 act contained no provision authorizing appeals from the territorial supreme court to the federal circuit court of appeals, instead limiting such review to the same narrow grounds available from state courts, and because no assignment of Hawaii to a federal circuit had occurred at the relevant time. The Court reasoned that Congress had expressly provided for pending admiralty cases to remain under territorial jurisdiction without special federal appellate rights, unlike cases filed after the act took effect.
The case concerned whether an insolvent debtor, Nelson, committed an act of bankruptcy under section 3(3) of the Bankruptcy Act of 1898 when a creditor obtained and enforced a judgment via a pre-existing confession-of-judgment clause on a promissory note, levying on his property, and Nelson took no steps to vacate the preference at least five days before the sale. The Supreme Court held that Nelson had not committed an act of bankruptcy. The Court reasoned that the 1898 statute, like its 1867 predecessor, requires a voluntary or intentional act by the debtor to create the preference; merely failing to file a voluntary bankruptcy petition or stop the creditor's lawful proceedings does not suffice. The Court therefore answered the certified questions in the negative.
The case concerned whether New York statutes required foreign vessels entering or leaving the port of New York via Sandy Hook to use a licensed pilot and whether a vessel owner could be sued at common law for damages caused by such a pilot's negligence on land. The court held that the statutes imposed compulsory pilotage, as they mandated taking a licensed pilot or paying pilotage fees to the first one offering services, penalized unlicensed piloting including by the master, and did not allow owners to freely select or avoid pilots. It further ruled that the suit proceeded under common law rather than admiralty jurisdiction because the harm occurred on land, and under common law an owner bears no liability for the fault of a compulsory pilot whose appointment is mandated by statute. The decision rested on the plain language of the 1857 and 1867 New York pilotage statutes, prior precedent in The China, and English common law authorities establishing that compulsion removes privity between owner and pilot.
The case Audubon v. Shufeldt concerned whether arrears of alimony owed by a bankrupt husband to his former wife could be discharged under the Bankruptcy Act of 1898. Robert Shufeldt, a retired army officer, sought bankruptcy discharge from various debts including $800 in alimony arrears granted by a Maryland court decree. The Supreme Court of the District of Columbia granted the discharge, but on appeal, the U.S. Supreme Court reversed, holding that alimony does not constitute a provable debt because it arises from the marital relationship and court decree rather than from contract or business transaction. The Court reasoned that alimony obligations are subject to modification by the granting court and are not enforceable like ordinary debts, thus not barred by bankruptcy discharge.
