towage
Definitions from Case Law · United States Supreme Court
Definitions from Case Law
From 285 U.S. 195 - Stevens v. The White City · 1932Most cited · 717 citing opinions
The supplying of power by a vessel, usually one propelled by steam, to tow or draw another is towage.
How the Supreme Court has restated “towage”
Each Supreme Court definition of “towage,” sized by how often later courts cited it. “Change” is measured by wording overlap with earlier definitions — a rough signal, not a semantic judgment.
How often courts cite the cases defining “towage”
Court decisions citing the 3 opinions that defined “towage” — 1,235 in all, by decade. Counts are citations to the defining cases as a whole, not verified uses of the term. The dip in the most recent years is a data-coverage gap, not a real trend — our corpus holds fewer opinions from the latest years.
All 3 definitions, chronological · 1871–1932
- ORIGINAL
an engagement to tow does not impose either an obligation to insure, or the liability of common carriers. The burden is always upon him who alleges the breach of such a contract to show either that there has been no attempt at performance, or that there has been negligence, or unskilfulness to his injury in the performance. Unlike the case of common carriers, damage sustained by the tow does not ordinarily raise a presumption that the tug has been in fault. The contract requires no more than that he who undertakes to tow shall carry out his undertaking with that degree of caution and skill which prudent navigators usually employ in similar services.
Towage does not involve bailment, and the services covered by the contract were less than towage