24 The Compact of 1785

the offender was a citizen. The Court held, however, that
these "piracies, crimes and other offenses," did not include
violations of the fishing laws, such violations having been
treated exclusively in Article 8. And, it continued, even
if Article 10 were regarded as a restriction upon the con
current jurisdiction given by Article 8, it would be appli
cable only to offenses against a citizen; here, there was no
averment of personal injury, but only of injury to the
State of Virginia.

 Accordingly, the Virginia court held that it had juris
 diction to try Hendricks, a citizen of Maryland,' and he
 was held to be guilty as charged.

 F. Potomac Steamboat Co. v. Upper Potomac Co. (1884).
 The Compact figured briefly, and negatively, in the Poto
 mac Steamboat Company case (109 U. S. 672) . The case
 involved a conveyance in 1791 of land to be part of the
 District of Columbia. The land fronted on the river. Sub,
 sequently, in 1797, the commissioners who were receiving
 title on behalf of the United States conveyed part of the
 same land back to the original grantor, with this differ
 ence, that the land so re-conveyed did not front upon the
 river, but only upon the north side (i.e., on the side away
 from the river) of a street running laterally with the river.
 The street was in 1797 marked upon the public plats of the
 plan of the city, and was not actually constructed until
 after the Civil War. The claim in the present case was
 that the original grantor still retained wharfage rights
 as appurtenant to his land on the north side of the street.

 1 This result in the Hendricks case was spoken of approvindiy by- the
Supreme Court of the United States. in Wharton v. Wise 11.53 1_'. S. 75;.
174). It N vas referred to mistakenly by a Federal Circuit Court, iii Ex pane
Marsh (57 Fed. 719, 729). which said that Ilendrick's defense `vas "per
fectly sound, and the Virginia Court of Appeal, sistailled this defense."
Actually, of course, the decision was against Hendricks.