In a significant expansion of the enforcement rights of foreign ship suppliers,

the U.S. Court of Appeals for the Fourth Circuit (covering the Mid-Atlantic

States) has held that fuel sold by a foreign supplier to a foreign ship in a

foreign port may give rise to a maritime lien. The decision has the potential for

increasing risks to those chartering out vessels. Owners have long been

responsible for liens incurred in the United States for such "necessaries" as

stevedoring, repair, supplies and towage, even when ordered by a charterer or

sub-charterer. Now, debts incurred worldwide are enforceable in the United

States courts, at least where the contract of supply has a United States choice-of-law provision.