. Dawson's commission has not been found. For an early example of his activity, see
Dawson v. Lighter and Molasses, Vice Adm. Min. Bk.
, 26 April 1768, discussed in No. 47, note
. See also No. 52
(1773). His activities against American shipping in the early years of the Revolution
are reported in William Bell Clark, George Washington's Navy
113–114, 125–128, 159–160 (Baton Rouge, 1960). Officers of the navy had long aided
in enforcing the Acts of Trade, although the scope of their authority was sometimes
questioned. See, for example, 12 Car. 2, c. 18, §1 (1660); Harper, English Navigation Laws
177–179. The Navy's success in halting trade with the enemy during the French wars
led, after 1763, to expanded authorization for naval officers to seize vessels violating
the Acts of Trade. 3 Geo. 3, c. 22, §4 (1763); 4 Geo. 3, c. 15, §42 (1764); 5 Geo.
3, c. 45, §26 (1765); see Ubbelohde, Vice Admiralty Courts
38–44, 116. The authority for their commissions was not in the statutes, however.
The Privy Council presumably directed the Commissioners of the Customs to deputize
naval officers. See Lord Egremont to Governor Bernard, 9 July 1763, 10 Bernard Papers
. Their shares of seizures were established by Order in Council, 8 July 1763, Book
of Charters, Commissions, Proclamations, &c., 1628–1763, fols. 254–257, M-Ar
. Probably the American Commissioners acted under the same authority after 1767. The
High Court of Admiralty in that year affirmed a decision of the Massachusetts Vice
Admiralty Court condemning a vessel seized by the first of these officers to present
his commission in Massachusetts in 1763. The question of the power to seize had been
raised in the lower court and seems to have been discussed on the argument in the
High Court, although the reported opinion there dealt with other questions. Bishop
v. The Freemason
, Quincy, Reports
387, 389–390 (Mass. Vice Adm., 1763), affirmed sub nom.
v. Bishop, Burrell
55, 167 Eng. Rep.
469 (High Ct. Adm., 1767). See No. 50, note 6
; No. 52, note 5