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ARTICLE · 16 JANUARY 2013

Supreme Court Decision Alert - January 15, 2013

Mayer Brown
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Under federal admiralty and maritime law, a "person providing necessaries to a vessel" has a maritime lien that may be enforced through an in rem civil action against the vessel.

United StatesLitigation, Mediation & Arbitration
Richard Katskee
Richard Katskee
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Keywords: federal admiralty jurisdiction, maritime lien

Today the Supreme Court issued one decision, described below, of interest to the business community.

Federal Admiralty Jurisdiction—"Vessel" Status

Lozman v. City of Riviera Beach, Florida, No. 11-626

Under federal admiralty and maritime law, a "person providing necessaries to a vessel" has a maritime lien that may be enforced through an in rem civil action against the vessel. 46 U.S.C. § 31342. The Rules of Construction Act, 1 U.S.C. § 3, defines "[t]he word 'vessel' [to] include[] every description of watercraft or other artificial contrivance used, or capable of being used, as a means of transportation on water." Today, in Lozman v. City of Riviera Beach, Florida, No. 11-626, the Supreme Court held that the petitioner's floating home was not a "vessel" for purposes of that Act.

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