Itel Containers International Corp. v. Atlanttrafik Express Service Ltd.
United States Court of Appeals for the Second Circuit
982 F.2d 765, 1993 AMC 609 (1992)
- Written by Carolyn Strutton, JD
Facts
Atlanttrafik Express Services Ltd (AES) (defendant) was a container-shipping line. AES chartered vessels from a number of owners for its shipping fleet. AES leased the containers it used in bulk from Itel Containers International Corp. and other container suppliers (the container suppliers) (plaintiffs). These containers were leased and delivered in large quantities to AES. The containers were not designated for use on any particular vessel operated by AES, and AES determined which containers would be used on which vessel. AES failed, ceased operations, and defaulted on its leases to the container suppliers. The container suppliers sued AES for breach of the leases and asserted in rem claims for maritime liens over the ships AES had chartered. The district court initially found in favor of AES and dismissed the container suppliers’ claims. After appeal, the case was remanded for findings of fact and conclusion of law for the lien claims. On remand, the court upheld the maritime liens over the vessels that AES had chartered. The vessel owners intervened as defendants and, with the vessels as defendants in rem, appealed the maritime-liens claims.
Rule of Law
Issue
Holding and Reasoning (Van Graafeiland, J.)
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