The Roanoke

Background

An Illinois corporation owned an ocean-going ship registered in Chicago that traded along the Pacific coast. Workers and suppliers provided materials and repairs after a local contractor ordered the work. The contractor had been paid in full before any claim was filed, and the shipowner did not know of the unpaid claims. The dispute arose under Washington law that declared contractors and subcontractors to be agents of a shipowner and allowed an automatic lien on vessels for such work.

Reasoning

The central question was whether a State may create liens against visiting or out-of-state ships in ways the general maritime law does not allow. The Court explained that admiralty and maritime matters are for the federal courts and that the general maritime rules limit when liens may attach to foreign or non‑home‑port vessels. While States can create liens for domestic ships, Washington’s statute went further. By treating contractors automatically as owners’ agents and creating absolute liens without notice protections, the law improperly interfered with federal admiralty authority. The Court therefore held the statute unconstitutional and reversed the lower court, ordering dismissal of the claims against the ship.

Real world impact

The decision prevents States from enforcing broad, retroactive liens on visiting or out‑of‑state vessels in conflict with federal maritime law. Vessel owners are protected from unexpected liens after contractors have been paid. States remain free to regulate repairs and liens for ships belonging to their own ports, but cannot override federal admiralty rules.

Dissents or concurrances

Justice Harlan joined the Court’s result in a concurrence, agreeing the Washington law could not stand.