Under the Commercial Instruments and Maritime Liens Act (CIMLA), 46 U.S.C. §§ 31301–31343, a party may obtain a maritime lien against a vessel by providing the vessel with “necessaries.” In Martin Energy Services, LLC v. Bourbon Petrel M/V, the US Court of Appeals for the Fifth Circuit held that a fuel supplier did not have a maritime lien for necessaries on a vessel owner’s three offshore supply vessels where the supply vessels carried the fuel as cargo in their cargo tanks to refuel other vessels. Continue reading >