 In United States v. <unk> ( 1820 ) , the Court held that § 12 of the Act did not extend to a manslaughter committed " in a river such as the river Tigris " because such was not on the " high seas . " ( Justice Washington had delivered an unrelated jury charge below . ) In United States v. Kelly ( 1826 ) , the Court interpreted the phrase " endeavour to make a revolt " to refer to " the endeavour of the crew of a vessel , or any one or more of them , to overthrow the legitimate authority of her commander , with intent to remove him from his command , or against his will to take possession of the vessel by assuming the government and navigation of her , or by transferring their obedience from the lawful commander to some other person . " Justice Washington , the author of the opinion of the Court , had written a slightly longer opinion below . 
