licies,[337] actions for towage[338] or pilotage[339] charges, actions
on bottomry or respondentia bonds,[340] actions for repairs on a vessel
already used in navigation,[341] contracts of affreightment,[342]
compensation for temporary wharfage,[343] agreements of consortship
between the masters of two vessels engaged in wrecking,[344] and surveys
of damaged vessels.[345] In the words of the Court in Ex parte
Easton,[346] admiralty jurisdiction "extends to all contracts, claims
and services essentially maritime."
MARITIME TORTS
Jurisdiction of maritime torts depends exclusively upon the commission
of the wrongful act upon navigable waters[347] regardless of the voyage
and the destination of the vessel.[348] By statutory elaboration, as
well as judicial decision, maritime torts include injuries to
persons,[349] damages to property arising out of collisions or other
negligent acts,[350] and violent dispossession of property.[351] But
until Congress makes some regulation touching the liability of parties
for marine torts resulting in the death of the persons injured, a State
statute providing "that when the death of one is caused by the wrongful
act or omission of another, the personal representatives of the former
may maintain an action therefor against the latter, if the former might
have maintained an action, had he lived, against the latter for an
injury for the same act or omission," applies, and, as thus applied, it
constitutes no encroachment upon the commerce power of Congress.[352]
PRIZE CASES, FORFEITURES, ETC.
From the earliest days of the Republic, the federal courts sitting in
admiralty have been held to have exclusive jurisdiction of prize
cases.[353] Also, in contrast to other phases of admiralty jurisdiction
prize law as applied by the British courts continued to provide the
basis of American law so far as practicable,[354] and so far as it was
not modified by subsequent legislation, treaties, or executive
proclamations. Finally, admiralty and maritime jurisdiction comprises
the seizure and forfeiture of vessels engaged in activities in violation
of the laws of nations or municipal law, such as illicit trade,[355]
infraction of revenue laws,[356] and the like.[357]
PROCEEDINGS _IN REM_
Procedure in admiralty jurisdiction differs in few respects from
procedure in actions at law, but the differences that do exist are
significant. Suits in admiralty take the form of a proceeding _in rem_
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