The Raithmoor

Background

A company working under a United States contract was building a concrete foundation pier to receive a gas beacon in the Delaware River when the steamship Raithmoor struck its scow, pile driver, the unfinished beacon structure, and a temporary wooden platform on the evening of July 18, 1909. The District Court awarded damages for the scow and pile driver but said it had no admiralty power over the claim for the beacon and platform. The structure stood in deep navigable water, was being built under government supervision, and was near completion.

Reasoning

The central question was whether the admiralty court could hear a tort claim for damage to a beacon that was still under construction. The Court explained that the beacon’s location in navigable water and its intended purpose as an aid to navigation gave the project a maritime character from the start. Because the injury arose from a continuous act on navigable water and the temporary platform was merely an incident to the beacon’s construction, the Court found the wrong to be maritime in nature and within admiralty jurisdiction.

Real world impact

The ruling reverses the dismissal and sends the beacon and platform claims back to the admiralty court for further proceedings. It means similar damage claims involving aids to navigation or construction in navigable waters can be heard in maritime courts, rather than being treated solely as land-based injuries.