Logistics Management Inc v One Pyramid Tent Arena - US Court of Appeals (9th Circuit)(Hall, O’Scannlain and Kleinfeld Ct JJ) - 18 June 1996

Admiralty jurisdiction - Whether determination of valid lien is a prerequisite for subject matter jurisdiction in respect of claim against cargo - Whether nonvessel-operating common carrier can have a maritime lien on cargo

The plaintiffs filed a complaint for foreclosure of a maritime lien against cargo in rem for unpaid freight, and for collection of tariff charges against the defendants in personam . The issues were (1) whether the Court had subject matter jurisdiction in respect of the plaintiffs’ in rem claim against the cargo and (2) whether a nonvessel-operating common carrier (NVOCC) could have a maritime lien on cargo.