Security Pacific National Bank v. The M/V Conquest

4 Am. Samoa 2d 59
CourtHigh Court of American Samoa
DecidedApril 21, 1987
DocketCA No. 17-84
StatusPublished

This text of 4 Am. Samoa 2d 59 (Security Pacific National Bank v. The M/V Conquest) is published on Counsel Stack Legal Research, covering High Court of American Samoa primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Security Pacific National Bank v. The M/V Conquest, 4 Am. Samoa 2d 59 (amsamoa 1987).

Opinion

On May 19, 1981, plaintiff Security Pacific National Bank lent $1.6 million to a corporation formed in order to purchase the M/V Conquest. The loan was secured by a "First Preferred Ship Mortgage," which was properly executed and recorded in Long Beach, California, in accordance with the Ship Mortgage Act, 46 U.S.C. 00 911 et seq. Plaintiff never received any payments on the loan.

In 1984 plaintiff filed this action to foreclose its mortgage. The action is in rem, and [61]*61service was effected by the seizure of the ship in Pagp Pago Harbor.

Soon after the seizure of the ship various suppliers of goods and services intervened, claiming maritime liens upon the Conquest and seeking the foreclosure of these- liens. The corporation that owned the ship never appeared. Plaintiff moved for summary judgment, claiming that its mortgage had priority over the maritime liens in accordance with the Ship Mortgage Act. The Trial Division of the High Court initially denied summary judgment on the ground that the Act grants exclusive jurisdiction to foreclose preferred mortgages to United States District Courts. See 46 U.S.C. '§ 951.

On plaintiff’s motion for reconsideration, however, the Trial Division reversed itself. The court held that Congress intended only to deprive state courts of jurisdiction to foreclose preferred mortgages. Prior to the passage of the Act in 1920, the federal district courts had exclusive jurisdiction over admiralty cases, including suits for the foreclosure of maritime liens; but since the English common law had treated ship mortgages as "non-maritime contracts," jurisdiction to foreclose them was generally in the state courts. See Bogart v. The Steamboat John Jay, 58 U.S. (17 How.) 399 (1854). Congress enacted the Ship Mortgage Act in order to put an end to this peculiar situation and to create a uniform set of priorities among mortgages and maritime liens throughout the United States, presumably including its territories and possessions. See Smith, Ship Mortgages, 47 Tul. L. Rev. 608 (1973). Accordingly, the High Court held that where there is "lacking a United States district court to exercise its ’exclusive,’ ’original.’ jurisdiction, the mortgage can be foreclosed in any court exercising valid admiralty jurisdiction." Security Pacific National Bank v. M/V Conquest, 4 A.S.R.2d 40, 41 (1985) (per Gardner, C.J.) [hereinafter cited as Conquest II.

Since there is no federal district court in American Samoa, and since the High Court has admiralty jurisdiction,1 the court foreclosed the [62]*62mortgage. The court also found that one intervenor, Star-Kist, had a preferred maritime lien for crew wages that took priority over plaintiff’s mortgage. All other liens (including some others held by Star-Kist) were subordinate to the mortgage.

Over a year later, after the Conquest had been sold and resold,2 the Appellate Division reversed the trial court’s decision. The three-judge appellate panel3 agreed with Chief Justice Gardner that "the exclusive jurisdiction provision was intended to provide uniform proceedings by removing [63]*63state jurisdiction over foreclosure actions," and that "the legislative history does not suggest that Congress intended to preclude foreign countries or territories from foreclosing on mortgages." StarKist Samoa, Inc., v. The M/V Conquest, AP No. 13-85, slip opinion at 9 (June 25, 1986) [hereinafter cited as Conquest II.1 The apparent intention of Congress, however, was classified as a "policy consideration" which the court was precluded from considering. Id. at 8-9. Rather, the appellate panel held that words mean what they say they mean and that the High Court of American Samoa "does not come within the plain meaning of ’district courts of the United States’" in 46 U.S.C. § 951. Conquest II at 4. The Appellate Division therefore remanded to the trial court "to determine the priority of [the] liens and to effect a foreclosure of the ship’s mortgage under common law admiralty principles." Id. at 12. This we shall now attempt to do.4

[64]*64I. Determining The Applicable Law

At the outset we must observe that the scope of our assignment on remand is far from clear. Technically there are no such things as "common law admiralty principles." Indeed, the historic separation between the English courts of common law and of admiralty is what gave rise to the problem we are dealing with. See G. Gilmore & C. Black, The Law of Admiralty § 1-4 (2d ed. 1975) [hereinafter cited as Gilmore & Black]. Moreover, [65]*65jurisdiction to foreclose a non-maritime mortgage was traditionally in equity rather than at common law. See Bogart v. The Steamboat John Jay, supra. We assume, however, that the Appellate Division was using the term, "common law" as a generic term for all non-statutory law. Thus we are to foreclose the ship’s mortgage and figure the priority of the liens by reference to whatever law may apply in the absence of> jurisdiction under the Ship Mortgage Act.

Plaintiff, the mortgagee, understandably suggests a narrow reading of the appellate decision. Notwithstanding the holding that we have no jurisdiction , under the Ship Mortgage Act, plaintiff urges that the' substance of the Act--in this case 46 U.S.C. § 953, which assigns preferred mortgages priority over all but a few maritime liens --- is binding on us. This solution is appealing not only in its simplicity but also in its consistency with the purpose of the Act. Nor would it violate the mandate of the Appellate Division, for it does not entail the construction of the term "United States District Courts" in the jurisdictional section of the Act (section 951) to include the High Court of American Samoa.

The language of section 953, however, seems to preclude the solution suggested by plaintiff. Instead of simply establishing certain priorities among liens and mortgages, it provides that the statutory priorities come into being only "[u]pon the sale of any mortgaged vessel by order of a district court of the United States." Until that moment, which, in Samoa is a moment that never comes, the ship’s mortgage and the maritime liens have whatever priorities they would have had in the absence of the statute. Insofar as we are bound by the directive of the appellate court to interpret the Act so as to give its words their most straightforward meaning rather than in light of their context and apparent purpose, section 953 would seem to be no more applicable than section 951 to proceedings in the High Court.

Intervenors also believe our task to be an easy one. It consists solely in consulting and applying court decisions rendered prior to the enactment of the Ship Mortgage Act in 1920. Under these decisions the holder of a ship’s mortgage "sat at the end of the table and received little or nothing." Gilmore and Black § 9-47 at 690.

[66]*66This view, however, misapprehends the role of a common law court. When a judge is dealing with judge-made rules rather than with legislation or a constitution, his task is not to apply old doctrines blindly to facts for which they were never made.

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Bluebook (online)
4 Am. Samoa 2d 59, Counsel Stack Legal Research, https://law.counselstack.com/opinion/security-pacific-national-bank-v-the-mv-conquest-amsamoa-1987.