The case involved the steamship Hirondelle, which was libeled and ordered sold in admiralty proceedings. Radiomarine Corporation of America intervened, seeking to have its radio equipment and automatic alarm on the ship set apart and not sold, claiming ownership under a contract where it installed and operated the equipment as a common carrier service. The court decided to release the equipment from seizure and return it to Radiomarine, reasoning that the radio apparatus was not part of the ship's essential tackle or furniture but instead belonged to and was used by the corporation in its separate regulated communications business, drawing on precedents distinguishing such specialized equipment from vessel property subject to liens.
This case involves a bill by Cleveland, a retail liquor dealer in Mobile, Alabama, seeking to enjoin the collection of a $1,000 excise tax under federal law (section 206, title 26 USCA) on top of the $25 license fee already paid, on grounds that Alabama prohibits liquor sales. The court first determined the suit was not premature because the collector had indicated intent to enforce the assessment via distraint. It then held that the $1,000 assessment, despite being labeled a tax, was in fact a penalty because it punished conduct illegal under state law, lacked revenue characteristics, and followed an already-collected tax on the same activity, making the anti-injunction statute inapplicable. The motion to dismiss was therefore overruled, allowing the equitable claim to proceed.
The case involved an indictment against the defendant on two counts: first, for knowingly receiving $10,000 from H. Edward Jackson, a bank employee who had embezzled funds, with intent to aid Jackson in avoiding detection; and second, for concealing Jackson and failing to report the offense to authorities. The defendant demurred to both counts, arguing deficiencies including that Jackson's embezzlement was not properly alleged as a felony and that no arrest warrant or duty to report was shown. The court overruled the demurrer to the first count, finding it valid under the accessory-after-the-fact statute, but sustained the demurrer to the second count. Core reasoning centered on whether Jackson's embezzlement under banking statutes constituted a felony or misdemeanor: although punishable by more than one year in prison, the statutes specifically designated it a misdemeanor, and section 541's general definition did not override these designations, so there was no felony for purposes of the misprision charge.
In United States v. Venturini, the defendant faced a two-count indictment for allegedly helping conceal H. Edward Jackson, a bank employee who embezzled $71,937.11 from a Federal Reserve member bank: the first count charged accessory after the fact under 18 U.S.C. § 551, and the second charged misprision of felony under 18 U.S.C. § 251 for failing to report the crime to authorities. The court overruled the demurrer to the first count but sustained the demurrer to the second count. It held that Jackson's embezzlement offense was a misdemeanor, not a felony, because multiple federal statutes, including the banking laws, explicitly designate it as such despite authorizing punishment exceeding one year. The core reasoning was that Congress's longstanding practice of specifically labeling offenses as misdemeanors controls over the general definition in 18 U.S.C. § 541, and that § 551 applies to any offense without requiring a prior warrant or arrest.
This case involved a suit by the Mobile Drug Company, a family-owned corporation, to recover income taxes it paid for 1918 after the government disallowed deductions for salaries paid to its officers. The salaries had been authorized by a January 9, 1918 board resolution that set amounts contingent on increased sales volume for that year, with partial credits entered on the books at year-end and final amounts credited on January 31, 1919 after confirming a 56% sales increase. The court held that the company was entitled to the deductions and ordered a refund of the protested payments, reasoning that the liability for the salaries accrued in 1918 under the resolution once the sales condition was met, even though the exact amounts could not be finalized until early 1919. The decision addressed the government's arguments on timing of accrual and statute of limitations but concluded the expenses were properly attributable to the 1918 tax year.
In Benson v. Crowell, an employer challenged a deputy commissioner's award of compensation to an injured worker under the Longshoremen’s and Harbor Workers’ Compensation Act, arguing that the Act violated Article III's grant of admiralty jurisdiction and the Fifth Amendment's due process clause by delegating final fact-finding to an administrative officer. The district court held that the Act could be construed constitutionally only if section 21(b) permitted a full de novo hearing in federal court on both facts and law, rather than limiting review to the administrative record or questions of law alone. The court reasoned that any narrower interpretation would improperly transfer judicial power from Article III courts to an executive agency and deny employers a meaningful opportunity to contest liability before their property was taken. It therefore overruled the motion to dismiss, placed the proceeding on the admiralty docket, and scheduled a hearing on the merits.