In the case of E. G. Rogers and L. F. Rogers, Merchants and Copartners, doing business under the name and style of E. G. Rogers & Co., Pooley, Nicoll & Co., owners of the schooner Ella; J R Brooks and F G Randolph, merchants and copartners doing business under the name and style of Brooks & Randolph; Thomas Sullivan trading under John Hurley & Co.; part owners of cargo on board said schooner Ella vs The Steamer St Charles James L Day Adam Wolf John Geddes Roger A Heirne Robert Geddes claimants - it was determined that a steamboat had collided with a sailing vessel in navigable waters resulting in damage to both vessels as well as their cargoes which were owned by different parties who had separate interests therein but were all entitled to compensation for damages sustained from such collision due to negligence or fault on behalf of either party involved in this incident

In the dissenting opinion of this case, it was argued that the appellants had not proven their claim to ownership of the cargo on board the schooner Ella. The court held that since there were no bills of lading or other documents proving title to any part of said cargo, they could not be considered as owners and therefore did not have a right to bring suit against those who claimed ownership. Furthermore, it was argued that even if there had been proof presented by the appellants showing title to some portion of said cargo, such evidence would still be insufficient for them to establish a valid claim in law due to lack of sufficient legal authority from which rights may arise. As such, it was concluded that without proper documentation establishing ownership over all parts of said cargo on board the schooner Ella, no action could be taken against those claiming otherwise.