In New Jersey Steam Navigation Company v. Merchants' Bank (1848) 47 U.S. 344, the owners of a steamboat, which was burned on Long Island Sound, were held liable for about $18,000 in coin, which had been shipped upon the steamer and lost. In consequence of the uneasiness produced among shipowners by this decision, and for the purpose of putting American shipping upon an equality with that of other maritime nations, Congress, in 1851, enacted what is commonly known as the Limited Liability Act The Supreme Court held that a contract of freightment is a maritime contract and upon a libel in admiralty the inquiry is into the nature and subject-matter of the contract and whether the service is a maritime service. Nelsom, J., referring to the contract in that case, said: "The language is general and broad, and might very well comprehend every description of risk incident to the shipment. But we think it would be going farther than the intent of the parties, upon any fair and reasonable construction of the agreement, were we to regard it as stipulating for willful misconduct, gross negligence, or want of ordinary care." The Supreme Court stated that in determining admiralty jurisdiction the inquiry is "into the nature and subject-matter of the contract, - whether it was a maritime contract, and the service a maritime service, to be performed upon the sea, or upon waters within the ebb and flow of the tide. And, again, whether the service was to be substantially performed upon the sea, or tide-waters, although it had commenced and had terminated beyond the reach of the tide; if it was, then jurisdiction has always been maintained." The Supreme Court held that a corporation engaged, under legislative authority, in the transportation of passengers and freight over navigable waters, was "in the exercise of a sort of public office, and has public duties to perform."