Maine Uniform Rental, Inc. v. Nova Star M/V, No. 16-2467 (1st Cir. 2017)Annotate this Case
The First Circuit declined to extend the reach of a maritime lien claim to encompass a pre-established purchase cost of items rented by a charterer pursuant to a temporary rental and service contract and affirmed the judgment of the district court limiting the in rem maritime lien claim of Appellant on the arrested ship, the M/V NOVA STAR.
Appellant’s claim arose from its agreement with the ship’s charterer to rent linens and other items for the ship’s ferry service. The district court refused to grant Appellant’s maritime lien claim in its entirety and entered judgment for Appellant in the amount of $16,187. The First Circuit affirmed the judgment of the district court, holding (1) the court properly limited the maritime lien to the amount of $16,187; and (2) the court correctly concluded that the inventory remaining in Appellant’s warehouse in Westbrook, Maine was not “delivered” in a manner as to create a maritime lien for its replacement cost according to the default provision of the rental contract.