World Fuel Services Singapore Pte. v. The Bulk Juliana

822 F.3d 766 (2016)

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World Fuel Services Singapore Pte. v. The Bulk Juliana

United States Court of Appeals for the Fifth Circuit
822 F.3d 766 (2016)

CS

Facts

World Fuel Services Singapore Pte. (WFS) (plaintiff) was a marine-fuel supplier. The Bulk Juliana was a vessel that was owned by Bulk Juliana Ltd. (defendant) and chartered by Denmar. Denmar entered into a contract with WFS for fuel to be delivered to the Bulk Juliana in Singapore. The contract stated that the transaction would be governed by United States general maritime law. Denmar failed to remit payment for the fuel and eventually became insolvent. WFS filed a complaint in federal district court in Louisiana, seeking the arrest of the Bulk Juliana, which was docked in New Orleans, and the recovery of the fuel purchase price. Bulk Juliana Ltd. posted security to have the vessel released and filed a motion for summary judgement to dismiss WFS’s complaint. Among other claims, Bulk Juliana Ltd. alleged that a contract between a supplier and the charterer of a vessel could not create a maritime lien over the vessel if the owner was not a party to the contract. The district court dismissed Bulk Juliana Ltd.’s motion, holding that the maritime lien against the Bulk Juliana was enforceable. Bulk Juliana Ltd. appealed.

Rule of Law

Issue

Holding and Reasoning (Jones, J.)

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