The question of priorities among maritime liens arises whenever the proceeds of sale of a ship are insufficient to satisfy all claims. The court must then proceed to the ranking of the claims to determine those which should be satisfied. Unfortunately, the law of maritime lien property is much like the sea itself in that it seldom appears the same twice. No doubt the confusion and uncertainty surrounding the topic are occasioned in part by the fact that the Supreme Court of the United States has had less to say about lien priorities than any other subject within the entire range of admiralty law.
Wentworth J. Marshall Jr., Maritime Lien Priority, 9 Clev.-Marshall L. Rev. 577 (1960)