The Robert W. Parsons, 191 U.S. 17 (1903) (No. 16)
1903
Case name: The Robert W. Parsons Opinion filed: 1903-10-26 Docket No.: 16 Citations: • 191 U.S. 17 • 24 S. Ct. 8 • 48 L. Ed. 73 • 1903 U.S. LEXIS 1495 Case holding summaries: • holding that a barge drawn by horses in the Erie Canal was a vessel because “[s]o long as the 9 No. 05-30963 vessel is engaged in commerce and navigation it is difficult to see how the jurisdiction of admiralty is affected by its means of propulsion” • navigability determined regarding admiralty jurisdiction • affirming navigability in fact test and rejecting influence of tides test • "neither size, form, equipment nor means of propulsion are determinative factors upon the question of jurisdiction, which regards only the purpose for which the craft was constructed, and the business in which it is engaged." • "Neither size, form, equipment, nor means of propulsion are determinative factors upon the question of jurisdiction, which regards only the purpose for which the craft was constructed, and the business in which it is engaged." • "the modern doctrine" is that "the actual navigability of the waters[] is the test of jurisdiction"
