Tilghman,  C.  J.,  in  Griffith  v.  Ins.  Co.,  5  Binn.  (Pa.),  464,466/".  (1813).
"  It  is  the  usage  of  American  vessels  to  take  sea-letters  in  voyages
to  Europe,  but  to  the  West  Indies  and  coastwise,  they  most  generally
sail  with  a  certificate  only.'^

Hoffman,  arguendo,  in  Slegbtr.  Bhinelander,  1  Johns.,  197.
'*The  title  to  a  ship  acquired  by  purchase  passes  by  writing.  A  bill
of  sale  is  the  true  and  proper  muniment  of  title  to  a  ship,  and  one  which
the  maritime  courts  of  all  nations  will  look  for,  and  in  their  ordinary
practice  require.  In  Scotland  a  written  conveyance  of  property  in
ships  has,  by  custom,  become  essential;  and  in  England  it  is  made  ab-
solutely necessary  by  statute  with  regard  to  British  subjects.  Posses-
sion of  a  ship  and  acts  of  ownership  will,  in  this,  as  in  other  cases  of
property,  be  presumptive  evidence  of  title,  without  the  aid  of  docu-
mentary proof,  and  will  stand  good  until  that  presumption  is  destroyed
by  contrary  proof;  and  a  sale  and  delivery  of  a  ship  without  any  bill  of
sale,  writing,  or  instrument  will  be  good  at  law  as  between  the  parties."

3  Kent  Com.,  130,  citing  The  Sisters,  5C.  Rob.,  IS.'S;  1  Mason,  139;  Weston  t.
Penniman,  1  tMd.,  306;  2  i&  id. » 435;  Ohlc.  Eagle  Ins.  Co.,  Aihid.,  390;  Codede
Commerce,  art.  195.  Robertson  r.  French,  4  East,  130;  Satton  v.  Buck,  2
Taunt.',  302;  Taggard  v.  Loring,  16  Mass.,  336;  Wendover  r.Hogleboom,
7  Johns.,  308;  Bixby  r.  Franklin  Ins.  Co.,  8  Pick.,  86.  Abbott  on  Ship.,
113;  The  Amclie,  6  Wall.,  18,  30;  Rice  v.  McLaren,  42  Me.,  157,  166;  Mc-
Mahonr.  Davidson,  12  Minn.,  357,  369,370;  The  Active,  01cott,286;  Fon-
taine V,  Beers,  19  Ala.,  722.
