Admiralty Arrest Procedures Fail The Due Process Test: Alyeska Pipeline Service Company v. Vessel Bay Ridge
The maritime lien plays an important role in facilitating the smooth operation of maritime commerce. Suppliers and others who do business with vessels are more likely to extend credit to even a strange or foreign ship because the remedy of a maritime lien is available. Without the lien the vessel would no longer serve as security for any contractual or tort liability she might incur and some other form of security would be required prior to dealing with the vessel. Arranging for letters of credit or similar security could prove costly and in some instances delay the vessel. Moreover, the importance of the maritime lien and in rem arrest is magnified by their universal acceptance in international maritime law. Because the lien is recognized throughout the world, it is a critical part of admiralty jurisprudence, and in United States' territories the only way it may be enforced is by the procedures of the Rule C in rem arrest.
Lance B. Nelson, Admiralty Arrest Procedures Fail The Due Process Test: Alyeska Pipeline Service Company v. Vessel Bay Ridge, 5 SEATTLE U. L. REV. 367 (1982).