Patterson v. Bark Eudora

Citations

• 190 U.S. 169
• 23 S. Ct. 821
• 47 L. Ed. 1002
• 1903 U.S. LEXIS 1544

Syllabus

<p>The title is no part of a statute. Where a statute declares that it shall apply to foreign vessels as well as vessels of the United States, the fact that its title states that it relates to American seamen cannot be used to set at naught the obvious meaning of the statute itself.</p> <p>Contracts for seamen’s wages are exceptional in character and may be subjected to special restrictions, and whenever they relate to commerce not Wholly within a State, legislation enforcing such restrictions comes within the domain of Congress under the commerce clause of the Constitution, and such legislation is not contrary to the Fourteenth or Thirteenth Amendment. '</p> <p>When Congress prescribes such restrictions, no one within the jurisdiction-of the United States can escape liability for a violation thereof on a.plea that he is a foreign citizen or an officer of a foreign merchant, vessel.The implied consent of this government to leave jurisdiction over the internal affairs of foreign merchant vessels in our harbors to the nations to which such vessels belong respectively may be withdrawn, and it is within the'power of Congress to protect all sailors shipping within our ports on vessels engaged in foreign or interstate commerce, whether foreign or belonging to- citizens of this country.</p> <p>Under the. act of Congress of. December 21, 1898, prohibiting the payment of seamen’s wages in advance, seamen shipped on a foreign vessel from : an American port to a foreign port and return to an American port who have received a. part of their wages in advance may, after the completion ,of the voyage, recover by libel filed against the vessel the full amount of , their wages including the advance payments, althdugh such payments 1 are not due either under the terms of the contract or under the law of • the country to which the vessel belongs.</p>