Tow-Boat

See Vessel. The weight of authority is that the owner of a steamboat engaged in the business of towing is not a common carrier.^ Towage. Drawing a vessel or other craft through the water from one place to another; also, the compensation or price for such service. A tug-boat (g. v.) is not a common carrier. Her captain or pilot must exercise reasonable skill and ' See 1 N. Y. Laws, 1867, c. 375; Laws, 1874, c. 12. a [State v. Pugh, 15 Mo. »511 (1852), Eyland, J. ' Barber v. Barber, 21 How. 586 (1858). * Be George Moncan, 8 Saw. 353 (1882): (3hinese Immigration Act, 6 May, 1882, § 3. '3 Kent, 314, cases. «See Caton v. Rumney, 13 Wend. 389 (1835); Alexander V. Greene, 8 Hill, 19 (1842); Wells v. Steam Nav. Co., 8 N. Y. 208 (1849); Leonard v. Hendrickson, 18 Pa. 41 (1851); Varble v. Bigley, 14 Bush, 702 (1879), cases. Contra, Smith v. Pierce, 1 La. •354 (1830); Adams v. New Orleans Steam Tow-boat Co., 11 id. *47 (1837); Walston V. Myers, 5 Jones L. 176 (N. C, 1857). Qutere. White V. The Mary Ann, 6 Cal. 470 (1866); Ashmore v. Pennsylvania Steam Towing Transp. Co., 29 N. J. L. care; the want of either will render her liable for all the damages resulting.^ / A " towage _Bervice " is rendered a vessel for;the purpose of expediting her voyage, without reference to any circumstance of danger. A " salvage service " is designed to relieve the vessel from some distress or danger, present or apprehended. ^ In the absence of a contract, the towing of a vessel iu peril or disabled is salvage; but as a convenient word to distinguish an ordinaiy case of contract from one of salvage "towage " is of ten used. The increased use of tugs, and their rivalry, have operated to reduce, the value of a salvage service in most ports to something not much beyond the price of a towage contract contingent upon success. Competition has established what might be called a quantum meruit for cases of this Mnd.3