French plaintiffs Chantier Naval Voisin and Bernard Voisin Sarl Les Sports Nautiques de Canne sued the yacht M/Y Daybreak in rem in Florida to recover amounts for services performed in France (repair work non-essential to navigation, and provision of supplies respectively). Certain other US providers of services/supplies intervened in the arrest action to assert maritime liens. The case was tried before the Court without jury.

The primary issue was whether US or French law applied to the existence/enforcement of the alleged maritime lien for services provided by the French plaintiffs. The Court held that French law regarding maritime liens, not the US lex fori, must apply to the French plaintiffs' claims. The plaintiffs cited art 9 of the Arrest Convention 1952 (disclaiming creation of any right of action under the Convention that would not otherwise arise under the law of the Court 'seized of the case', as well as the creation of any maritime lien that does not otherwise exist under such law) to argue that because the Florida court was 'seized of the case' by way of the in rem arrest, US law must apply. The Court rejected this argument and construed art 9 of the Arrest Convention 1952 as merely a clarifying statement that the Convention does not create substantive rights, and instead simply provides the procedure applicable for prosecution of whatever rights exist under the substantive law applicable according to the jurisdiction’s choice-of-law rules.

Held: French substantive law applied under a substantial-contacts analysis and the Supreme Court’s Lauritzen factors (Lauritzen v Larsen, 345 US 571, 73 S Ct 921, 97 L Ed 1254 (1953)), and French substantive law governed the existence (or not) of a maritime lien claim. Accordingly, because French law (namely the French Law of 4 January 1967) and art 2 of the MLM Convention 1926 (to which France is a signatory) included substantially identical provisions restricting maritime liens for necessaries solely to 'those contracts "necessary for the preservation of the vessel, or the continuation of its voyage"', which is much more restrictive than the US law of maritime liens for necessaries, the Court awarded the plaintiff Chantier Naval recovery for certain repair services necessary for preservation of the vessel/continuation of the voyage, but denied the claim of Bernard Voisin on the grounds that the supplies provided were not 'necessaries' under French law.

The Court also noted that French law and the MLM Convention 1926 provide a six-month time bar for any maritime lien for supplies, and a one-year time bar for any maritime lien for services. Both plaintiffs' claims were brought after the respective time bars had run. However, the Court did not dismiss the claims as time-barred, relying on the inherent equitable power of US courts in admiralty, and thus applying laches to find the claims were not time-barred (based in large part on the fact that a partial payment plan had been agreed, and certain payments made toward the debt in the interim before suit was filed).