Patterson v. Bark Eudora

Background

Congress passed an 1898 law that makes it a crime to pay seamen wages in advance and says that rule applies to foreign ships as well as American ones unless a treaty says otherwise. The dispute arose after sailors signed on in New York for service aboard a British merchant vessel and received advance payments; challengers argued the law exceeded federal power, violated sailors’ freedom to contract, and that British law should control work done on a British ship.

Reasoning

The Court addressed whether Congress may forbid advance wage payments to sailors and apply that ban to foreign merchant vessels while they are in U.S. ports. The Justices said the statute plainly says it applies to foreign vessels and that the liberty to make contracts is not absolute. Because a sailor’s work is treated as special and ocean voyages touch interstate and foreign commerce, Congress may set rules to protect commerce and seamen. The Court also explained that when foreign merchant ships enter U.S. ports they submit to U.S. law unless a treaty provides otherwise, so the statute is within Congress’s power and enforceable here.

Real world impact

The ruling means sailors who sign on in U.S. ports are protected from exploitative wage advances, and foreign merchant ships calling at U.S. ports must follow the same no-advance-wages rule as American ships. The decision also helps U.S. vessels compete for crews by preventing widespread advance payments in large ports.

Dissents or concurrances

One Justice (Harlan) agreed with the final decision in judgment.