Admiralty by virtue of her Majesty's immediate commission to her Majesty's 
governors, having been lately by her Majesty's special directions set aside, so 
that the said Courts in all her Majesty's plantations are now wholly under the 
direction of his Royal Highness the Lord High Admiral, and such as are 
commissioned by him in each plantation." 293 
For a few years following this focus of administrative attention, the jurisdictional 
question remained dormant. But in 1711 the question as to the 
authority by which vice-admiralty courts were held in the plantations was 
again raised by Secretary Dartmouth and was deviously "answered" by the 
Board of Trade by reference to the terms of the vice-admiral commissions 
given to all governors whereby the governors were empowered to appoint 
a deputy or deputies for determining all maritime affairs and to the clause in 
the gubernatorial commissions authorizing the constitution of courts. 294 In 
the same year we find an opinion by Sir Charles Hedges that in case of any 
complaint or appeal from proceedings in plantation vice-admiralty courts, 
all sentences in civil and maritime causes were to be determined by the High 
Court of Admiralty in England. Upon failure of justice in that court, the final 
determination was to be in the Court of Delegates. 205 In March, 1715/6, Advocate 
General Lloyd was questioned by the Board of Trade whether an 
appeal from the New York Vice-Admiralty Court condemnation of the ship 
Eagle for illegal trading had been heard as yet in the High Court of Admiralty 
208 Lloyd replied that the appeal had been dropped, but added, "Not 
that but the appellants might have reheard the cause here. For by law appeals 
doe lie from the Admiralty Courts in the Plantations, to the Lord High Admiral 
in the High Court of Admiralty of England, in common maritime 
causes." 20T Furthermore, in 1720 Richard West, legal adviser to the Board 
of Trade, in answering a reference as to use of prohibitions by colonial common 
law courts against the vice-admiralty courts, declared it "irregular" to 
appeal to the King in Council from sentences of the latter courts. From such 
293 6 H. of L. MSS (n.s.) 92. 
2si CSP, Col., 1711-12, #122, 141; JCTP, 
1708/9-1714/1 5, 302-3. 
295 Aim. 1/3668/109; Sir Charles Hedges to 
Josiah Burchett, October 19, 1711: "I conceive 
the Admiralty jurisdiction in the plantations 
is on the same foot as those of the Vice- 
Admirals are here in England, and the proceedings 
there are or ought to be carryed on 
in the same method as they are in the Admiralty 
courts here." 
296 CSP, Col, 1716-17, #84. In this case the 
Eagle arrived from the coast of Guinea with 
a cargo of negroes. After making legal entry 
in New London, Connecticut, the ship 
anchored off the coast of Long Island, New 
York, where many of the negroes were disposed 
of. Then, when coming into New York 
Harbor the ship was seized for violation of 15 
Charles 11, c. 7, condemned on Aug. 16, 1715, 
and an appeal taken to the High Court of 
Admiralty {ibid., 1714-15, #629 viii). Governor 
Hunter was eager to have the sentence 
affirmed as essential to enforcement of the 
Acts of Trade in the province {ibid., #629, 
673). 
297 Ibid., 1716-17, #90.