Admiralty Jurisdiction and State Waters

The case of Ex parte Boyer1 closes with the statement that it "does not raise the question whether the admiralty jurisdiction of the district court extends to waters wholly within the body of a state, and from which vessels cannot so pass as to carry on commerce between places in such state and places in another state or in a foreign country; and no opinion is intended to be intimated as to jurisdiction in such a case." Nor does any other case appear directly to intimate such an opinion, unless it be that of Stapp v. Clyde2 wherein a state court decided that a federal statute giving to district courts jurisdiction over "the navigable waters of the United States" did not apply to navigable waters of the state wholly unconnected navigably with those of other states, there being a distinction between waters of a state and those of the United States. This holding was declared without discussion or reasons given and appears not since to have been elucidated. It is thus left an open question whether or not the potential admiralty jurisdiction of the Federal courts extends to such state waters.