law lien has a right to appear as a technical "claimant." (The Two Marys, 12 Fed. Rep. 152.) So a watchman has no lien unless his services are for the benefit of all on board. (The Erinah, 7 Fed. Rep. 231.

Enforcement of maritime lien.-The admiralty has general jurisdiction to enforce maritime liens. (The America, Newb. Adm. 195; The Nestor, 1 Sum. 73; The Spartan, 1 Ware, 149; Davis v. Child, 2 Ware, 78; Cutler v. Rae, 7 How. 729.) If the subject-matter is maritime, the lien may be enforced, although it arises under a State law (The Missouri, 9 Blatchf. 433), or by common or local law. (The Island City, 1 Low. 375; The Illinois, 6 McLean, 413; The Marion, 1 Story, 68.) Its jurisdiction to enforce a maritime lien is exclusive (Killam v. The Eri, 3 Cliff. 456); so admiralty will enforce a lien conferred by a foreign law. (The Pawashick, 2 Low. 142; The Havana, 1 Sprague, 402; The Wexford, 3 Fed. Rep. 577; The Enterprise, 1 Low. 455.) Where the lien is given by the maritime law, it is a question of comity. (The Maggie Hammond, 9 Wall. 435.) The question as to the true limits of the admiralty jurisdiction is judicial, and no statute or act of Congress can make it broader than the judicial power may determine. (The Lottawanna, 21 Wall. 558; The St. Lawrence, 1 Black, 525.) It is not every case where the lien exists by local law that the admiralty will enforce it. (A New Brig, 1 Story, 244.) State legislatures have no authority to create maritime liens (Leon v. Galceran, 11 Wall. 185; The John Richards, Newb. Adm. 73; Ths Alaska, 3 Ben. 391; Hobart v. Drogan, 10 Peters, 108); but a State law may give a substantial right which may be enforced by the appropriate remedy (Ex parte McNeil, 13 Wall. 236); so, if it gives a master a lien for his wages, he may enforce it by a proceeding in rem in admiralty. (The Mary Gratwick, 2 Sawy. 342.) It is immaterial whether the claim could be enforced in rem, for the remedy will be afforded according to the lex fori. (The Boston, Blatchf. & H. 309; The Champion, 1 Brown Adm. 520; The Maggie Hammond, 9 Wall. 435.) A maritime lien may be enforced by proceedings in personam if the property has passed into the hands of third parties. (Sheppard v. Taylor, 5 Peters, 675; Cutler v. Rae, 7 How.

729.) When there can be no lien until there is a seizure, it cannot be enforced in admiralty. (The Samuel Strong, 6 McLean, 587.) It has jurisdiction to enforce a lien against third persons who have purchased the property subject to the lien. (Buckman v. Dunn, 16 Bank. Reg. 470.)

Lien for advances.-A person who lends money for the purpose of repairs or furnishing supplies is entitled to the same privilege as one who repairs or supplies the vessel (The Union Express, Brown Adm. 539; The Horatio, Bee, 167; The Boston, Blatchf. & H. 309; The Medora, 2 Wood. & M. 92; Davis v. Child, 2 Ware, 78; The Lulu, 10 Wall. 192); so one who advances money to release a vessel from an attachment may sue in admiralty to recover it (The J. R. Hoyle, 4 Biss. 234); or who releases her by means of a stipulation. (The Hoyle, 4 Biss. 238; The Romp, 2 Abb. U. S. 31; The Robertson, 10 Chic. L. N. 220.) The shipwright cannot sue in a port where there is a consignee with ample funds (The Horatio, Bee, 167; Emily Souder, 17 Wall. 606); so the admiralty has no jurisdiction over an action by a broker or agent to recover a balance due for advances. (Minturn v. Maynard, 17 How. 477.) If a party loans money to be used in the purchase of a vessel, and takes a power of attorney to sell her as security, the agreement is not maritime. (The Perseverance, Blatchf. & H. 385.) A party stipulating for the release of a vessel, and paying the amount of the decree, does not thereby become subrogate to the rights of the former lien-holder. (The Robertson, 8 Biss. 180.) Money advanced to purchase commodities to be shipped to the officers of the boat creates no lien. (The Josephine Spangler, 9 Fed. Rep. 773.) A lien for borrowed money is on the same footing as that for which it was borrowed. (The Guiding Star, 9 Fed. Rep. 521.)

For materials and supplies.-Any contract made to equip, fit, or furnish a vessel after she is launched and afloat is a maritime contract. (The Eliza Ladd, 3 Sawy. 519.) The admiralty has jurisdiction over actions for supplies and materials furnished to foreign vessels. (The Jerusalem, 2 Gall. 349; The Sandwich, 1 Pet. Adm. 233;

The Nestor, 1 Sum. 73; The Ida Stockdale, 22 Pittsb. L. J. 9.) So supplies furnished in one State to a vessel belonging to another are furnished to a foreign vessel. (The Thales, 20 How. Pr. 147; The Charles Meares, Newb. Adm. 197; The Chusan, 2 Story, 455; The Nestor, 1 Sum. 73; The Superior, Newb. Adm. 176; The Henrietta, Newb. Adm. 2S4: The Hilarity, Blatchf. & H. 90; The Stephen Allen, Blatchf. & H. 175; The Medora, 2 Wood & M. 92). The lien attaches for provisions, although the creditor knows that the master took the vessel on shares, and that he is to victual and man her if furnished on the credit of the vessel. (The Monsoon, 1 Sprague, 37; The Sara Starr, 1 Sprague, 453; The Phebe, 1 Ware, 263; Webb v. Pierce, 1 Curt. 104; Freeman v. Buckingham, 18 Bow. 182; Thomas v. Osborn, 19 How. 22; Pratt v. Reed, 19 How. 359.) A maritime lien does not attach to a canal-boat for family supplies. (The T. L. Wadsworth, 13 Fed. Rep. 46.) A contract to furnish nets to a fishingvessel is a maritime contract. (Lord v. The Hiram R. Dixon, 33 Fed. Rep. 297.) A contract for supplies and fuel, and for services performed, is a maritime contract. (Jutte v. Davis, 21 Pitts. L. J. N. S. 94.)

Over bottomry bonds.-Admiralty jurisdiction extends over bottomry bonds by whomsoever executed (The Jerusalem, 2 Gall. 191; The Mary, 1 Paine, 671; The Draco, 2 Sum. 157), and irrespective of the completion or non-completion of the voyage (The Draco, 2 Sum. 157); but the instrument must have the essentials of a bottomry bond (The Medora, 2 Wood. & M. 92), as the jurisdiction depends on the subject-matter of the contract (The Mary, 1 Paine, 671); the test being the subject-matter for which the thing is pledged (The Medora, 2 Wood. & M. 92), and maritime risks must be incurred. (The Atlantic, Newb. Adm. 514.) The bond may be given by the owner at the home port, where there is an express pledge as security (The Draco, 2 Sum. 157), and although the money was not borrowed for the purpose of the voyage. (The Draco, 2 Sum. 157; but see The Allitta, Crabbe, 326.) If the hypothecation is to procure materials and supplies in a foreign port without assuming maritime risks, it is not cognizable in admiralty (The At

lantic, Newb. Adm. 514); and if a bill is drawn it must share the fate of the bond. (The Atlantic, Newb. Adın. 514.)

Mortgages. A mortgage on a vessel is not a maritime contract (The John Jay, 17 How. 399; The Angelique, 19 How. 239; The Ernest and Alice, 2 Hughes, 70; The Medora, 2 Wood. & M. 22), and admiralty cannot enforce the lien. (People's Ferry Co. v. Beers, 20 How. 293; The John Jay, 3 Blatchf. 67; The John and Alice, 1 Wash. C. C. 295; Deshon v. The Medora, 3 Wood. & M. 118. See The Hilarity, Blatchf. & H. 90.) The admiralty has no jurisdiction of a possessory action brought by a mortgagee. (Morgan v. Tapscott, 5 Ben. 252; The W. D. Rice, 3 Ware, 134; The Martha Washington, 3 Ware, 245.)

Liens conferred by State statutes. A state law may give a lien not already cognizable in admiralty, and authorize its enforcement in rem. (The America, 34 Cal. 676; The John Shallcross, 35 Ind. 19; Edwards v. Elliott, 21 Wall. 332; The Alabama Belle, 20 La. An. 432; The R. R. Roberts, 46 Ind. 476; Wyatt v. Stuckley, 20 Ind. 279; The Mollie Doster, 24 Iowa, 192; The Richard Busteed, 100 Mass. 400; T..e Fanny Barker, 40 Mo. 235, 253; The Magnolia, 44 Mo. 67; The Magnolia, 45 Mo. 69; Hussen v. Hassam, 45 Miss. 133; Fisher v. Luling, 33 N. Y. Sup. 337; Murphy v. Salem, 8 N. Y. Sup. 140; Sheppard v. Steele, 43 N. Y. 52; Fralick v. Betts, 20 N. Y. Sup. 632; The M. Tuttle v. Buck, 23 Ohio St. 565. See the City of Erie v. Caufield, 27 Mich. 479; Nicholson v. State, 3 Har. & McH. 109.) A State law may give a lien for repairs in the home port, and confer jurisdiction on a State court to enforce it by a personal action and attachment against the vessel (The Hyatt v. Reitz, 4 Bush, 395; The Starlight, 103 Mass. 227,) or writ of sequestration. (Leon v. Ga!ceran, 11 Wail. 185.) And a State court may issue such attachment in an action brought to enforce a maritime contract. (Albany City Ins. Co. v. Whitney, 70 Pa. St. 248; Switzer v. Heinn, 27 La. An. 25.) So the proceeding by attachment may be against an owner, and his interest be subjected to sale in a State court (Hine v. The Tre

vor, 4 Wall. 555; Corwin v. Foy, 4 W. Va. 721; Merritt v. Peabody, 40 Ga. 177); but it must be in a suit in personam (Habaerle v. Barringer, 29 La. An. 140); and under the State process, whatever its name, the vessel may be held to answer the final judgment (Southern Dry Dock Co. v. The J. D. Perry, 23 La. An. 39); but a State law cannot create a maritime lien and confer jurisdiction in the admiralty in rem (The Sylvan Grove, 9 Fed. Rep. 335), as on a contract not maritime (The Pacific, 9 Fed. Rep. 120); nor for negligently causing the death of a person. (The Sylvan Grove, 9 Fed. Rep. 335.) State legislatures may create liens on domestic vessels, founded on maritime contracts (The Belfast, 7 Wall. 624; The Harrison, 1 Sawy. 355; The Edith, 10 Blatchf. 466; The New Brig, Gilp. 521); but it cannot provide for the enforcement in rem (The Edith, 10 Blatchf. 466; The Kalorama, 10 Wall. 204; The Beifast, 7 Wall. 625); nor give any other than a common-law remedy. (Leon v. Galceran, 11 Wall. 185; The Circassian, 12 Am. Law. Reg. 291; The Edith, 10 Blatchf. 466.) Alien given by State law for materials and repairs furnished to a vessel in a home port may be enforced in admiralty. (Aitcheson v. The Endless Chain Dredge, 40 Fed. Rep. 253.) A state statute cannot effect the admiralty or maritime jurisdiction, or the operation of the maritime law in maritime cases. (Butler v. Boston & S. Steamship Co., 130 U. S. 527.) Courts of admiralty cannot be controlled by State legislation in the distribution of the proceeds of vessels sold under admiralty process, but will recognize liens created by State statute and assign them to the class to which they belong under the maritime law of priority, where they will share equally with other liens of the same class. (The Menominie, 36 Fed. Rep. 197.) A lien on a ship given by State statute may be enforced in admiralty. Id.

Enforcement of liens given by State law.-Liens given by the State law at the home port of a vessel will be recognized (The General Tompkins, 9 Fed. Rep. 620; The Guiding Star, 9 Fed. Rep. 521); and enforced in admiralty in a suit in rem (The City of Salem, 10 Fed. Rep. 843,) subject to the qualification of the State law. (The Alida, Abb. Adm. 165; The Barges, 6 Penn. L. J.