BML Stage Lighting, Inc. v. Mayflower Transit, Inc.
This case addresses whether a carrier can assert a lien on property owned by a third party who was not involved in the shipping contract. Mayflower Transit, Inc. claimed a lien on lighting equipment belonging to BML Stage Lighting, Inc. and Carbine Management, Inc. after the lessee, SportsLab, Inc., failed to pay transportation and storage fees and declared bankruptcy. The trial court sided with Mayflower, but BML appealed. The appellate court examined both contractual and common law lien claims. It determined that no contractual lien existed because BML was a stranger to Mayflower's contract with SportsLab, and there was no evidence of apparent authority. The court also ruled that Mayflower acted as a contract carrier, not a common carrier, in this specific instance, thus precluding a common law lien. Therefore, the appellate court reversed the judgment, finding no valid lien, and remanded for a new trial on BML's conversion claims.