Crowell v. M'Fadon

12 U.S. 94 (1814)

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Crowell v. M'Fadon

United States Supreme Court
12 U.S. 94 (1814)

Facts

John M’Fadon (plaintiff) shipped 650 barrels of flour and five tons of logwood from the port of Baltimore on a vessel named Union. After the vessel had departed the port of Baltimore but before it reached its final destination, the United States Congress passed the Act of 25 April, 1808 (the act) placing an embargo on cargo vessels. While the Union was en route to its destination, Joseph Crowell (defendant), a United States revenue inspector, boarded the vessel. Believing that the Union was transporting cargo in violation of the act, Crowell seized the Union and its cargo. As required by the act, the president of the United States reviewed Crowell’s decision and confirmed the seizure. M’Fadon brought a trover action against the United States and Crowell, arguing that the seizure constituted unlawful conversion of the seized assets. The Massachusetts Supreme Judicial Court ruled in favor of M’Fadon, awarding damages for the unlawful conversion. Crowell appealed to the United States Supreme Court.

Rule of Law

Issue

Holding and Reasoning (Duvall, J.)

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