Overview
Case summary
This case involves appeals by the owner of coasting steamers from district court decrees granting maritime liens to suppliers for coal and water furnished to the vessels. The supplies were delivered at wharfs during short coastwise trips, in small quantities for daily use, with the master present but owner and charterers absent. The owner argued supplies were furnished on charterers' credit, with libelants having notice, and on charterers' orders. The Circuit Court affirmed, holding that such supplies furnished under these circumstances create a prima facie presumption they were furnished with the master's acquiescence, binding the vessel, even if orders came from engineers or subordinate agents. The court found the owner failed to rebut this presumption by proving libelants knew orders came from charterers.
Abstract
Appeals were filed by the owner of coasting steamers challenging district court decrees that granted maritime liens to suppliers for coal and water furnished to the vessels during short coastwise trips. The supplies were delivered in small quantities for daily use at wharfs with the master present but owner and charterers absent, and the owner argued they were furnished on the charterers' credit with notice to suppliers. The court affirmed, holding that such supplies create a prima facie presumption of being furnished with the master's acquiescence, binding the vessel, which the owner failed to rebut by proving suppliers knew orders came from charterers.
Opinion of the court
opinionPUTNAM, Circuit Judgejoined by COLT, WEBB
- Supplies furnished in master's presence create presumption of acquiescence
- Impractical to require proof of express orders for routine supplies
- Owner failed to rebut presumption by showing libelants knew of charterers' involvement
Jurisdiction
not challenged- Appeals from decrees on libels against coasting steamers for supplies of coal and water
Procedural posture
- Whether supplies were furnished on credit of vessel vs. charterers
- Whether libelants had notice of charter
- Whether supplies were furnished on order of master/owners vs. charterers
- Laches on part of libelants
- Lack of proof coal went aboard steamer
Legal categories
Case record
Issues & holdings
Clearly erroneous
Court found supplies furnished on credit of vessels based on evidence
Issue preserved for review
Clearly erroneous
Court found owner failed to prove libelants had such notice
Issue preserved for review
Clearly erroneous
Court found supplies furnished with master's presumed acquiescence regardless of who gave immediate orders
Issue preserved for review
Holdings of the court
Error analysis
- District court should have found supplies furnished on charterers' credit, with libelants' notice, and on charterers' orders — evidentiary · no error foundCourt reviewed evidence and found no error in factual findings · not applicable
- Laches by libelants and lack of proof coal went aboard — procedural · error forfeited
Burden of proof
- Presumption shifts burden to owner to prove libelants had notice of charterers' involvement
Standards of review
- Factual findings regarding credit, notice, and orders — clearly erroneous Issues raise pure questions of fact involving weighing contradictory testimony
Timeline
Circuit Court of Appeals issues opinion affirming district court decrees
Outcome: Decrees affirmed
Final disposition of appeals establishing presumption for maritime liens
Facts & evidence
Incident
Key facts
6 facts- Owner of coasting steamers appealed decrees on libels for supplies of coal and water
- Supplies furnished at wharfs at ports of touch during short coastwise trips
- Supplies delivered in small quantities as needed for daily use
- Master present and in control during deliveries
- Owner and charterers absent during deliveries
- Some orders given by engineers or subordinate agents
Disputed questions
- Whether supplies furnished on credit of vessel or charterers
- Whether libelants had notice of charter
- Whether orders came from master or charterers
Procedural history
3 steps- Libels filed against steamers for supplies
- District court found for libelants
- Owner appealed
Evidence in the record
- Witness testimony apparently contradictory on who gave orders
- Engineer testimony about written orders from charterers which proof failed
- Supplies delivered at wharf with master present
- Usual course of business for engineers to order coal
- Telephone messages from Boston sometimes received
- Evidence type: Testimony about orders · Challenge basis: Whether orders came from master or charterers · Trial court ruling: admitted · Reasoning: Court weighed testimony and found presumption of master's acquiescence · Challenged on appeal: true · Appellate outcome: affirmed
Objects of relevance
Authorities
Standards & doctrines
- Prima facie presumption of master's acquiescence for maritime liens
- Clearly erroneous standard for factual review
Legal principles applied
- Supplies furnished in master's presence create presumption of acquiescence binding vessel
- Practical impossibility of requiring proof of express orders for daily supplies