Huus v. New York & Porto Rico Steamship Co.
Headline: Court upholds that an American steamship operating between Puerto Rico and New York is part of the coastwise trade, so New York’s pilotage law requiring state pilots does not apply.
Holding: The Court held that an American-built, enrolled and licensed steamship carrying trade between Puerto Rico and New York was engaged in the coastwise trade and thus New York’s pilotage laws did not apply.
- Allows enrolled coastwise steamships to avoid state pilotage rules when operating coastwise.
- Treats trade with Puerto Rico as domestic coasting trade.
- Limits state power to require state pilot licenses for federally licensed coastwise steam vessels.
Summary
Background
The dispute involved the steamship Ponce, an American-built vessel owned by a New York corporation, enrolled and licensed for the coasting trade by U.S. authorities, and trading between Porto Rico and New York. New York law generally required vessels engaged in foreign trade to take a state-licensed pilot, and the State’s Consolidated Act included provisions about pilotage for vessels entering or leaving New York harbor.
Reasoning
The Court addressed whether the Ponce was a coastwise seagoing steam vessel under federal law and actually employed in the coasting trade under New York law. The opinion reviews federal statutes that let the States regulate pilotage except for certain coastwise steam vessels licensed by the United States, and it considers congressional and executive measures that treated trade with Porto Rico as part of the domestic coasting trade. The Court concluded that the Ponce was engaged in the coasting trade and that federal enrollment and licensing placed her outside New York’s pilotage rules.
Real world impact
Because the Ponce was held to be a federally enrolled and licensed coastwise steam vessel, New York could not require a state pilot or collect pilot charges for her. The decision treats trade between Porto Rico and the United States as part of the coasting trade for these purposes and confirms that federally licensed coastwise steam vessels are governed by federal rules rather than state pilotage laws.
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