The following are digests and case links to Circuit Court Admiralty Cases that have as an issue maritime arrest/in rem action:

Thypin Steel v. Asoma Corporation
Second Circuit Court of Appeals
May 25, 2000

Maritime Arrest/In Rem Action: Supplemental Admiralty Rule D explicitly applies to an in rem possessory action to acquire title to maritime property, a category under which a bill of lading clearly falls, thus the plaintiff was entitled to arrest a bill of lading pursuant to Rule D and obtain in rem jurisdiction.

R.M.S. Titanic v. The Wrecked and Abandoned Vessel
Fourth Circuit Court of Appeals
April 12, 2002

Salvage/In Rem Action: R.M.S. Titanic, Inc. ("RMST") is the salvor-in-possession of the submerged wreck R.M.S. Titanic and artifacts salvaged from the wreck. But RMST's salvage lien in the artifacts has not converted to title in the artifacts. RMST must first complete the salvage service that it intends to perform and have its salvage reward determined. Only after its reward is determined can it seek to enforce the lien against the artifacts themselves.