Southwest Marine of Samoa, Inc. v. The M/V Kwang Myong 71

On Motion for Reconsideration:

Plaintiff seeks reconsideration of the court’s decision and order denying plaintiff’s motion for "default judgment in rem." Among other things, plaintiff argues clear error on the court’s part "in concluding that the Plaintiff’s claim for moorage charges is not maritime in nature and that a maritime lien against the vessel does not therefore exist."

The court did not, as plaintiff seems to argue, hold that moorage charges may not give rise to maritime liens.1 Rather, the court found on the evidence that the M/V Kwang Myong #71 was not a vessel in *154navigation and…