Trailer Bridge v. LA Intl Marine

Summarized by John Slack ,
6 hours 18 min ago

Case Type:

Business

Case Status:

Affirmed

Citation:

25-30331 (5th Circuit, Jun 11,2026) Published

Tag(s):

Ruling:

The Fifth Circuit Court of Appeals affirmed the District Court's judgment and held that a maritime lien had attached to the Barges because the lienholder had no actual knowledge of the underlying no-lien provision when it agreed to provide necessary services to the company chartering the Barges. Further, the Fifth Circuit upheld the District Court's calculation of the lien and found that the court did not abuse its discretion in denying the lienholder's request for attorney's fees and in its award of prejudgment interest.

Procedural context:

The Fifth Circuit Court of Appeals explained that under the Commercial Instruments and Maritime Liens Act (CIMLA), LIM obtained a maritime lien because it provided necessary services to the Barges and Work Cat, who chartered the Barges and was therefore an authorized agent of the Barges' owner, had the authority to obtain these services for the Barges. Trailer Bridge argued that a lien was not formed because LIM relied exclusively on the credit of Work Cat and not the Barges' credit, but Plaintiff was unable to rebut the presumption that a maritime lien formed here. As for the no-lien provision in the Barge Charter, the Fifth Circuit explained that such a clause only prevents the formation of a maritime lien if the entity providing necessary services had actual knowledge of the clause. The court did find that LIM had actual knowledge of the provision when it received a copy of the Barge Charter on December 20, 2020, but Work Cat's agreement with LIM was finalized in November. Therefore, because LIM did not have actual knowledge of the no-lien clause before signing off on the tugboat agreement, the provision did not prevent the formation of the liens. The Fifth Circuit also ruled that the CIMLA eliminated a necessary supplier's duty to investigate whether a no-lien provision applied to the Barges. Finally, both Plaintiff and LIM argued on appeal that the District Court incorrectly calculated the value of the lien, but the Fifth Circuit upheld the trial court's calculation as it correctly reflected the value of the towage services provided to the Barges and excluded expenses relating only to the tugboats. The Fifth Circuit then ruled that the District Court did not abuse its discretion when it denied LIM's request to have its attorney's fees awarded in personam against Trailer Bridge because 46 U.S.C. § 31343(c)(2) does not require the court to grant attorney's fees and there was no separate basis for Trailer Bridge to be liable to LIM beyond the lien. Finally, the court ruled that Trailer Bridge's argument that LIM's claims were discharged in the Work Cat bankruptcy proceedings was not persuasive and Plaintiff's argument that the award of prejudgment interest was an abuse of discretion was also unavailing.

Facts:

In August of 2020, Plaintiff/Appellant Trailer Bridge, Inc., a freight service company, chartered two oceangoing barges to Work Cat Trans Gulf ("Work Cat"). Plaintiff chartered the Atlanta Bridge and Memphis Bridge Barges (the "Barges") pursuant to a Standard Barge Charter Party Agreement (the "Barge Charter"), which contained a "no-lien" clause that required Work Cat to "indemnify and hold [Plaintiff] harmless against any lien of whatsoever nature arising upon the [Barges]" during the contract period. During this same time, Work Cat also chartered two tugboats from Defendant/Cross-Appellant Louisiana International Marine, LLC ("LIM") to provide towage services to the Barges. The agreement between LIM and Work Cat was executed in November of 2020 and was to last six months, beginning in December of 2020, and required Work Cat to pay a daily rate for the tugboats along with other incidental expenses. While Work Cat used the tugboats through June of 2021, it failed to pay for a majority of LIM's invoices during this time. In May of 2021, Work Cat filed for bankruptcy and Plaintiff and LIM both filed proofs of claim. Further, LIM also filed two notices of lien claims valued at $1,364,214.16 against the Barges and later demanded Plaintiff to cover its unpaid invoices, which Trailer Bridge refused to pay. Trailer Bridge then sold the Barges to third parties and LIM sent a notice of the lien and a demand for payment to one of the purchasers. Pursuant to the purchase agreement terms between Trailer Bridge and the purchaser, Plaintiff stepped in to defend and indemnify the purchaser and filed a lawsuit for a declaration that the Barges were not subject to LIM's lien. Both LIM and Trailer Bridge sought to recover attorney's fees. Additionally, LIM filed a third-party claim against the Barges, in rem, to recover for unpaid towage services and related expenses. The District Court conducted a two-day bench trial and ruled that LIM held a lien against the Memphis Bridge for $863,162.50 and against the Atlanta Bridge for $630,420.10 and awarded LIM attorney's fees in rem. Trailer Bridge was not a party to the initial judgment, so LIM moved to add Trailer Bridge as a party so it could recover attorney's fees in personam. After reviewing the motions, the District Court changed its mind and refused to award either party attorney's fees. Trailer Bridge then appealed on behalf of the Barges and LIM cross-appealed.

Judge(s):

Jones, Stewart, and Willett

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