Silver Star Enterprises, Inc. v. Saramacca MV
United States Court of Appeals for the Fifth Circuit
82 F.3d 666, 1996 AMC 1715 (1996)

- Written by Carolyn Strutton, JD
Facts
Scheepvaart Maatschappij Suriname N.V. (SMS) operated a fleet of cargo vessels, including the M/V Saramacca (defendant). SMS leased cargo containers in bulk from Trans Ocean Ltd. (plaintiff) to use in its fleet. The lease agreement allowed SMS to determine on which vessels to deploy the containers and also allowed for the containers to be used in other modes of transportation on land or in the air. Silver Star Enterprises, Inc. (Silver Star) (plaintiff) held two preferred ship mortgages over the Saramacca and commenced an in rem action against the vessel after the Saramacca went into default. Trans Ocean came into the action to claim maritime-lien rights for unpaid leasing fees for its containers that had been used on the Saramacca. The Saramacca was seized and eventually sold at auction, and the proceeds were deposited in a registry of the court for division among the claimants. The district court found that Trans Ocean was entitled to a maritime lien, granted partial summary judgment to Trans Ocean, and determined that Trans Ocean’s lien claim was superior to Silver Star’s mortgage claim. Silver Star appealed.
Rule of Law
Issue
Holding and Reasoning (Jones, J.)
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