In 1841, the U.S. ship William Brown sank after hitting an iceberg. Crewmen, including Alexander William Holmes, believed that their overloaded lifeboat was in danger of itself sinking and put 14 or 16 passengers overboard to their inevitable deaths in the frigid water. On his return to Philadelphia, Holmes was arrested and charged with murder. The grand jury rejected the indictment and substituted manslaughter.[20] The judge in the United States Circuit Court for the Eastern District of Pennsylvania instructed the jury that necessity might be a complete defence but that "before the protection of the law of necessity can be invoked, a case of necessity must exist, the slayer must be faultless, he must owe no duty to the victim." The jury convicted Holmes and the principle of necessity was not tested by any higher court. He was sentenced to six months in jail and a $20 fine.[21] This case was also cited in defence of Dudley and Stephens.