## Facts

- The steamer *Lottawanna* was a domestic vessel owned and based in New Orleans, Louisiana.
- Seamen filed an admiralty libel in federal district court in Louisiana seeking unpaid wages.
- Materialmen who provided repairs and supplies to the vessel in New Orleans intervened, asserting liens against the vessel for their claims.
- The dispute centered on whether, independent of any state statute, the general maritime law recognized a maritime lien for repairs and supplies furnished to a vessel in her home port.
- Prior Supreme Court decisions and admiralty practice had generally denied an implied maritime lien for such home-port services absent state law.

## Issues

1. Whether the general maritime law, as received in the United States, creates a maritime lien for materialmen who furnish repairs and supplies to a vessel in her home port, independent of state statute.
2. What legal force “general maritime law” has in the United States, and how it relates to the Constitution’s admiralty jurisdiction, federal legislation, and state law.
3. Whether federal courts may alter substantive maritime law by recognizing new maritime liens, or whether such changes must come from legislatures.

## Decision

- The Supreme Court held that materialmen furnishing repairs and supplies to a vessel in her home port do not obtain a maritime lien under the general maritime law as adopted in the United States.
- The Court refused to create such a lien by judicial decision, stating that substantive changes to maritime law must be made by the legislative branch rather than the courts.
- The Court indicated that Congress has power to create a uniform lien regime for materialmen, and that states may legislate in this area where Congress has not acted and the subject is not exclusively federal.
- The Court treated the absence of a general home-port lien as settled by repeated prior adjudications and related admiralty practice.

## Legal Principles

- The “general maritime law” has domestic effect only to the extent it is adopted by a nation’s own law and usage; it has no independent force by itself.
- The Constitution’s grant of admiralty and maritime jurisdiction incorporates a national maritime law, but the content of that law depends on received maritime usage, competent legislation, and controlling judicial precedents.
- Defining the limits of admiralty jurisdiction is a judicial function; within those limits, courts generally declare existing maritime law but do not make substantive changes such as creating new liens.
- Under U.S. maritime law, no implied maritime lien arises for repairs and supplies furnished to a vessel in her home port unless a lien is provided by applicable legislation.
- In the absence of federal regulation, states may enact lien laws affecting vessels where the subject does not require exclusive federal control, subject to federal admiralty jurisdiction and governing federal rules.

## Conclusion

The Court maintained the rule that home-port materialmen have no maritime lien under general U.S. maritime law, emphasized that substantive lien creation is for legislatures rather than courts, and recognized room for state lien statutes until Congress enacts a uniform federal scheme.


The Lottawanna, 88 U.S. (21 Wall.) 558 (1874)