Note and Comment

Maritime Liens – Personality of Ship – In Coal Company v. Fisheries Company (Advanced Sheets, Nov. 15, ig2o), the Supreme Court denies a lien for supplies of coal furnished the owner of a fleet of vessels for use thereon and, incidentally, brings into stronger relief the admiralty doctrine of the personality of the ship as distinguished from that of the owner. At the time the arrangement was made, the shipowner was without money or credit and could not enter upon its operations without a supply of coal for its ships and factories. The Coal Company agreed to supply its requirements on the understanding that, while some of the fuel would be used on shore, the greater part would be consumed by the vessels and that it would have a maritime lien therefor. All deliveries were made at the shipowner’s factories and. the ships were fueled from its bins in quantities of which accurate accounts were kept. Towards the close of the season of navigation, the vessels were sold under a foreclosure of mortgage and the Coal Company asserted its lien by proceedings in rein against them. In affirming the decree of the Court of Appeals dismissing the libels, the Supreme Court points out that the maritime lien provided by the Act of June 23, 191O, rests upon a furnishing of supplies to the vessel and not to the owner for such appropriation to the vessel as he