In the case of Henry T. Bulkley, Claimant of the Barque Edwin v. The Naumkeag Steam Cotton Company, Bulkley appealed a decision by the District Court that found him liable for damages to goods shipped on his vessel from Liverpool to Boston in 1855. He argued that he was not responsible as he had no control over how and when his ship was loaded or unloaded and thus could not be held accountable for any damage caused during transit. The Supreme Court ultimately agreed with Bulkley's argument and reversed the lower court’s ruling, finding that it would be unjust to hold him liable since he had no control over what happened while at sea or in port after loading occurred. This case set an important precedent regarding liability for cargo owners who have limited involvement in shipping operations but are still potentially exposed to legal action if something goes wrong during transport.

In the case of Henry T. Bulkley, Claimant of the Barque Edwin v. The Naumkeag Steam Cotton Company, Justice Grier delivered a dissenting opinion in which he argued that it was not necessary for the claimant to prove his title to the vessel before being able to recover damages from an opposing party who had wrongfully seized and detained it. He reasoned that since there was no dispute as to ownership between Bulkley and any other person or entity, then proving title should not be required in order for him to receive compensation for losses incurred due to wrongful seizure by another party. Furthermore, he stated that even if proof of title were necessary under such circumstances, this would only apply when there is a dispute over ownership between two parties; however this did not exist in this particular case because neither Bulkley nor The Naumkeag Steam Cotton Company contested each other's claim on the vessel at hand. Therefore Justice Grier concluded that requiring proof of title would be unnecessary and unjustified given these facts and circumstances surrounding them matter at hand.