Trinity Yachts, LLC v. Mike & Jerry’s Paint & Supply, Inc. (2014)
Decided: December 11, 2014. Citation: 152 So. 3d 286 (Miss. 2014).
Facts
A paint supplier to an independent yacht-finishing contractor asserted watercraft liens. Agreed orders released the vessels with money substituted in the court registry. opinion-trinity-pdf ms-ch85 cornell31307
Holding
Summary judgment for Trinity affirmed for lack of privity with owner/authorized agent when the supplies were furnished. The separate interlocutory appeal challenging § 85-7-31’s constitutionality was dismissed; constitutionality was NOT decided. The later withholding/payment arrangement did not retroactively create privity. opinion-trinity-pdf ms-ch85 cornell31307
Reasoning
Majority applied the owner/agency requirement and distinguished later promises from the original supply relationship. The concurrence separately relied on in-state/direct-supply language. Dissents challenged importing privity, emphasized agreed fund substitution and contractual/unjust-enrichment theories; those positions were not the majority’s holding, and unjust enrichment was not the pleaded claim resolved on appeal. opinion-trinity-pdf ms-ch85 cornell31307
Practical impact
A product used aboard a vessel does not by itself prove this state lien. The decision concerns the state lien; federal maritime jurisdiction/preemption remains a separate inquiry. opinion-trinity-pdf ms-ch85 cornell31307
Good-law status and treatment
Full thirty-five pages reviewed, including concurrence and both dissents. Checked 2020–2026 code-section indexes identify no enacted replacement of § 85-7-7’s pertinent text. Targeted treatment did not reveal an overruling decision; no assertion that the seizure statute was upheld or that all maritime liens were adjudicated. opinion-trinity-pdf ms-ch85 cornell31307
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