Alaska Steamship Co. v. United States
Headline: Court allows payment to shipowners for transporting shipwrecked seamen from Alaska, overturning Comptroller General’s refusal and enforcing long-standing administrative practice using deputy customs certificates.
Holding: The Court held that the statutes require the government, not the shipowner, to transport destitute seamen and that deputy customs collectors’ certificates authorize payment under the long-standing administrative practice.
- Allows shipowners to be paid for transporting shipwrecked seamen from Alaska when certified by customs.
- Affirms long-standing administrative practice and federal appropriations fund transportation costs.
- Prevents Comptroller General from denying payment contrary to statute and practice.
Summary
Background
A shipowner sought payment from the United States for carrying the crew of his wrecked ship from Ketchikan, Alaska, to Seattle. The crew boarded the owner’s other vessel after a deputy customs collector signed a transportation certificate and the owner billed the government. The suit was brought under the Tucker Act in federal court in Western Washington, and the owner sought payment under the shipping laws at an agreed rate. The Comptroller General refused payment, claiming the law requires certification by a consular officer and that the owner must transport his own crew. Lower courts dismissed the claim, and the owner appealed to the Supreme Court.
Reasoning
The Court examined the statutes, appropriations, and a long administrative practice extending back decades. It found Congress had repeatedly funded transportation for shipwrecked American seamen, including those in Alaska, and the Bureau of Navigation had supplied forms to Alaska customs officials who regularly issued certificates. The Court concluded the certificates signed by deputy customs collectors in Alaska carried the force Congress had intended and that no statute imposed on an owner a duty to transport his own wrecked crew. The Court also explained that courts should follow a settled administrative construction when Congress's annual appropriations implicitly approve that practice. The Comptroller General’s refusal conflicted with the statutes and settled administrative practice and therefore could not stand.
Real world impact
Owners who transport shipwrecked American seamen from Alaska can be paid when transportation is certified by Alaska customs officers under the long-standing federal practice. The decision upholds long-used payment procedures and requires the government to fund transportation for destitute seamen, rather than shifting that burden to shipowners. Congress remains free to alter the rules by new law if it chooses.
Ask about this case
Ask questions about the entire case, including all opinions (majority, concurrences, dissents).
What was the Court's main decision and reasoning?
How did the dissenting opinions differ from the majority?
What are the practical implications of this ruling?