[365] 5 How. 441 (1847). See also New Jersey Steam Nav. Co. v. Merchants' Bank, 6 How. 344 (1848). Aside from rejecting English rules, Waring v. Clarke did not affect the rule concerning the ebb and flow of the tide, inasmuch as the collision occurred within the ebb and flow of the tide, though within the body of a county. Citing Peyroux v. Howard, 7 Pet. 324 (1833); The "Orleans" v. Phoebus, 11 Pet. 175 (1837); The "Thomas Jefferson," 10 Wheat. 328 (1825); United States v. Coombs, 12 Pet. 72 (1838).
[366] 12 How. 443 (1852).
[367] Soon afterwards in Jackson v. Steamboat Magnolia, 20 How. 296 (1858), the Court rejected what was left of narrow doctrines of the extent of admiralty jurisdiction by holding that a collision on the Alabama river above tidal flow and wholly within the State of Alabama came within the grant of admiralty jurisdiction in the Judiciary Act of 1789 which extended it "to rivers navigable from the sea * * * as well as upon the high seas."
[368] See Warren, II, 512-513.
[369] 109 U.S. 629 (1884); see also Perry v. Haines, 191 U.S. 17 (1903) where the admiralty jurisdiction was extended to inland canals.
[370] 10 Wall. 557 (1871).
[371] Ibid. 563. See also The Montello, 20 Wall. 430 (1874), where this doctrine was applied to the Fox River in Wisconsin after it had been improved to become navigable.
[372] 141 U.S. 1, 12-15 (1891). This case contains a good review of admiralty cases to the time of its decision.
[373] 311 U.S. 377, 407-410 (1940).
[374] 316 U.S. 31, 41 (1942).