Weems Steamboat Co. of Baltimore v. People's Steamboat Co.

Background

A Maryland transportation company owned or leased a number of wharves along the Rappahannock River. A Virginia transportation company began stopping at and using those same wharves for passengers and freight despite protests. The Virginia company offered to pay for use, but the Maryland company refused and sought an injunction to keep the rival off its wharves. A master found the Maryland company owned five wharves and leased eight others, and that prior public use had been at most a license, not a formal public dedication or condemnation.

Reasoning

The Court addressed whether a private waterfront owner must allow others to use private wharves simply because the wharves are convenient or previously used by the public. The Court said private wharves on a navigable river are private property, subject to the public right of navigation but not automatically open to all users. The Court relied on state law and prior decisions to hold that mere public use does not create a public right unless the owner intended to dedicate the wharf and a public authority accepted it, or the wharf was taken by public authority with compensation. Because the master found only a license and no dedication or condemnation, the owner could exclude the rival carrier. The Court reversed the lower court and ordered an injunction to stop the rival’s use.

Real world impact

Private waterfront owners can exclude competing carriers from private wharves when there has been no formal dedication or public taking. Competing transport companies must secure access by agreement, build new landings, or seek public authority to create a public wharf with compensation. The ruling enforces exclusive property rights while recognizing that public authorities can acquire wharves if needed.