Summary

Edward Douglass White Simmons v. The Steamship Jefferson…

Useful services of any kind rendered to a vessel or her cargo, exposed to any impending danger and imminent peril of loss or damage, may entitle those who render such services to salvage reward.
'Persons assisting to extinguish a fire on board a ship, or assisting to tow a ship from a dock where she is in imminent danger of catching fire, are as much entitled to salvage compensation as persons who render assistance to prevent a ship from being wrecked, or in securing a wreck or protecting the cargo of a stranded vessel.
Source: Wikisource

Edward Douglass White Simmons v. The Steamship Jefferson…

In the nature of things it is manifest, and indeed it is settled, that, because of the broad scope of the admiralty jurisdiction in this country, the perils out of which a salvage service may arise are all of such perils as may encompass a vessel when upon waters which are within the admiralty jurisdiction of the United States; from which it follows that the right to recover for salvage services is not limited to services concerning a peril occurring on the high seas or within the ebb and flow of the tide.
Source: Wikisource

Edward Douglass White Simmons v. The Steamship Jefferson…

There is in reason no distinction between the continued control of admiralty over a vessel when she is in & dry dock for the purpose of being repaired, and the subjection of the vessel when in a dry dock for repairs to the jurisdiction of a court of admiralty for the purpose of passing upon claims for salvage services, by which it is asserted the vessel, while in the dock, was saved from destruction.
Source: Wikisource

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