Central Boat Rentals v. M/V Nor Goliath, No. 21-60501 (5th Cir. 2022)
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Epic Companies, LLC ("Epic") was a general contractor specializing in the decommissioning of oil platforms. Epic hired the vessel Nor Goliath to lift oil platform components out of the water. These components were then transported to shore by tugboats, which were owned by various other companies.
When Epic went bankrupt, the company's suppliers filed suit in the district court to recoup their costs. Several towing companies joined in the suit, asserting maritime liens under the Commercial Instruments and Maritime Liens Act ("CIMLA") against the Nor Goliath. The towing companies claimed that they provided "necessary services" by towing the barges ashore. The district court granted summary judgment in Nor Goliath's favor.
The Fifth Circuit affirmed. CIMLA provides that those who provide "necessary services" to a vessel obtain a maritime lien against the vessel and may bring a civil claim to enforce this lien. Under 46 U.S.C. Sec. 31301(4), necessary services include repairs, supplies, towage, and the use of dry dock or marine railway. Here, the Nor Goliath's role was to lift platform components out of the water and place them on barges. Thus, the Nor Goliath's necessaries were the goods and services used to accomplish this task, but not those related to Epic's larger goal of decommissioning oil platforms. Thus, the Fifth Circuit held that the towing companies did not perform necessary services to the Nor Goliath.
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