In Bulkley v. Naumkeag Steam Cotton Company (1860) 65 U.S. 386, the barque was libeled to recover damages for not delivering part of the cotton - 707 bales - which the master had agreed to carry from Mobile to Boston. With most of the cargo on board the vessel was towed below the bar, there to receive the remainder from lighters. A lighter carrying 100 bales sank, and the cotton was lost or damaged. The barque delivered 607 bales at Boston in good condition. The owner of the vessel claimed exemption for her upon the ground that she never received the 100 bales. In that case, the barque Edwin received the principal part of her cargo at the city of Mobile. Due to the peculiar conditions at Mobile, after the Edwin had received part of her cargo she was towed down below the bar to receive the residue. The master of the Edwin employed the steam lighter M. Streck for this purpose, and 100 bales of cotton were taken aboard the M. Streck at the city to be taken down to the Edwin. On the way down, the boiler of the lighter exploded, the 100 bales were thrown into the water and the lighter sunk. The court held that delivery to the lighterman was delivery to the master, and that transportation by the lighter to the master was commencement of the voyage, in execution of the contract to carry the cotton to Boston. It was authoritatively decided that when the carriage begins from the lighter's point of departure the lighter is the substitute for the ship, and the liability arises as soon as the lighter receives the goods. The Supreme Court said: "In the present case the cargo was delivered in pursuance of the contract, the goods in the custody of the master, and subject to his lien for freight, as effectually as if they had been upon the deck of the ship, the contract confessedly binding both the owner and the shipper; and, unless it be held that the latter is entitled to his lien upon the vessel also, he is deprived of one of the privileges of the contract, when, at the same time, the owner is in the full enjoyment of all those belonging to his side of it." It was laid down that the lien of the shipper attaches when the goods are delivered to the master or his agent to be transported by the ship. The court said: "There is no necessary physical connection between the cargo and the ship, as a foundation upon which to rest this liability" (the shipper's lien).