Scharrenberg v. Dollar Steamship Co.
Headline: Court rejects claim that seamen brought from abroad are 'contract laborers,' upholds lower courts, and rules sailors on American merchant ships in foreign trade are not imported to work in the United States.
Holding: The Court held that seamen hired to serve on American merchant ships engaged in foreign trade are not "contract laborers" performing labor "in the United States," so the defendants did not violate the 1907 Act.
- Stops applying 1907 contract-labor penalties to merchant seamen hired for foreign voyages.
- Affirms lower courts and Department practice excluding seamen from immigrant labor rules.
- Makes nationality (e.g., Chinese) irrelevant to this exclusion.
Summary
Background
This case was brought by a party seeking penalties against three shipping corporations and a shipmaster who operated two steamships. The complaint alleged they arranged in Shanghai to have a Chinese man sign on as a seaman on one ship, discharged him in San Francisco, and then had him sign as a seaman for an American ship bound for Asia. The plaintiff argued these actions knowingly brought an "alien contract laborer" into the United States in violation of the 1907 contract-labor law.
Reasoning
The Court examined the statute’s definition of "contract laborer" as someone induced to migrate to perform work in this country. It concluded that a "seaman" is commonly and legally a sailor or mariner, not a "laborer" in the sense used by the law. The Court also rejected the idea that an American-flag merchant ship engaged in foreign trade counts as the physical territory of the United States so that seamen aboard are working "in this country." The opinion relied on earlier decisions and longstanding agency practice to reach this interpretation.
Real world impact
Because the hired men were bona fide seamen serving in foreign commerce, they did not fall within the statute’s protection as contract laborers and the penal claims failed. The Court affirmed the lower courts’ dismissal of the complaint. The fact that the seamen were Chinese did not change the legal result. The ruling leaves intact prior practice excluding merchant seamen from the 1907 contract-labor penalties.
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