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The New Orleans, 106 U.S. 13 was a case heard by the United States Supreme Court in 1882. The case involved a dispute between the owners of the steamboat, The New Orleans, and the owners of the steamboat, The City of New Orleans. The owners of The New Orleans claimed that the owners of The City of New Orleans had wrongfully taken possession of The New Orleans and refused to return it. The owners of The City of New Orleans argued that they had a right to take possession of The New Orleans because they had a valid lien on the vessel. The Supreme Court held that the owners of The City of New Orleans did not have a valid lien on The New Orleans and that the owners of The New Orleans were entitled to the return of their vessel. The Court reasoned that the lien was invalid because it was not properly recorded in the proper public records. The Court also held that the owners of The City of New Orleans had wrongfully taken possession of The New Orleans and were liable for damages. The New Orleans, 106 U.S. 13 is an important case because it established the principle that liens must be properly recorded in the proper public records in order to be valid. This case also established that wrongful taking of possession of a vessel is actionable and that the owners of the vessel are entitled to damages.
In the case of The New Orleans, a majority opinion was issued by the United States Supreme Court. However, Justice Field dissented from this opinion and argued that the city of New Orleans had no authority to impose taxes on vessels entering its port. He reasoned that Congress had exclusive power over interstate commerce and any attempt by a state or municipality to interfere with it was unconstitutional. Furthermore, he noted that while states have certain powers under their police regulations they cannot use those powers in such a way as to impede upon federal laws governing interstate commerce. In conclusion, Justice Field believed that since Congress has exclusive control over navigation between states any attempts by local governments to tax vessels would be an infringement on congressional power and therefore unconstitutional.