Anderson v. Pacific Coast Steamship Co.

Background

This case involved rules about who must serve as a pilot when steam vessels enter or leave ports. The parties were state authorities enforcing California pilot laws and the broader federal system of pilot licensing. The opinion traces how early Congress left pilotage to the States, then passed several federal laws in the 1800s that sometimes required federal pilots for certain coastwise steam vessels but also added a proviso preserving state pilot rules in many cases.

Reasoning

The main question was whether federal law forces registered coastwise steam vessels to use federal pilots, or whether States can require local pilots for those registered ships. The Court examined the history and the specific language of the statutes (including the 1871 provisions now in the Revised Statutes) and concluded that Congress required federal pilots only for coastwise steam vessels not sailing under register. For vessels that do sail under register, the federal rules do not supply a compulsory federal pilot and therefore do not block State laws requiring local pilots. The Court answered each certified question in the negative.

Real world impact

As a result, ship operators of registered coastwise steam vessels remain subject to state pilotage rules when entering or leaving ports. The federal pilot requirement continues to apply only to non-registered coastwise steamers. Congress, not the courts, would have to change that balance if it wanted federal pilotage rules to cover registered vessels in the future.