We come next to consider liens, or rights in the nature of lien, acquired by process of law, and those imposed by statute, for the protection of the claims of the government An attachment on mesne process does not exactly correspond to a lien, either in the sense of the common law, or of maritime law, or of equity. It is only a contingent, conditional charge until the judgment and levy, (q) Goods attached are in the custody of the law for the benefit of all parties concerned, and the plaintiff has not a lien on them, (r) An officer loses his claim upon goods attached by him, if he leaves them in the hands of a receiptor, and the latter delivers them to the debtor. They may be disposed of by the debtor, or taken from him again on a new attachment (s) A judgment lien, binding the present and future real property of the debtor, is a creation of statute law, and has no other existence. Such a lien cannot survive the law which created it, and it must be created by the government under whose laws the judgment is rendered. This consideration becomes of importance in the courts of this country, owing to the independent powers of the several States, and of the general government, in respect to the subject of legal remedies. Thus, a State may determine the effect as to liens of the judgments of its own courts, but not that of judgments of the courts of the United States; and a similar limitation applies as to the legislation of Congress, (t)

(n) Demainbray v. Metcalf, Prec in C. 419.

(o) Via. Abg. tit. Pawn (E); Anon. 2 Salk. 522; Parks v. Hall,2 Pick. 206; Walter v. Smith, 5 B. ft Ald. 439.

(q)) Ex parte Foster, 2 Story, 131. (r) Melville v. Brown, 1 Harr. 333. (s) Robinson v. Mansfield, 13 Pick. 139. (t) Corwin v. Benham, 2 Ohio (N. s.)36 36.

A general lien by judgment on land does not constitute per se a property in the land itself, but only gives a right to levy on the same, to the exclusion of adverse interests subsequent to the judgment; and such levy when made relates back to the * time of the judgment, (u) Among other liens provided for by statute is that upon lands for the payment of taxes, assessed by government upon the owners thereof. In the case of land taxes assessed to non-residents, the Supreme Court of Massachusetts has decided, that they are only a lien upon the land, and not a personal charge, (v) The United States government has also a lien upon goods imported, for the payment of the duties; and, by the excise law, it is provided, that the duties assessed upon the products of manufacturing and other labor, and upon income, shall be a lien upon all the property, whether real or personal, of the party taxed, (w)

By the English statutes, specialty crown debts, when duly recorded in the Court of Common Pleas, are a lien upon the debtor's real estate, and remain so, until a quietus in behalf of the debtor or accountant to the crown be registered. Simple contract debts to the crown are a lien upon chattels personal; but if they have the force and effect of debts of record, as by ministerial or judicial record, they attach to the land possessed by the debtor, as well as his chattels personal, (x)

Statutes conferring liens for the benefit of mechanics and other artisans, usually prescribe certain forms of proceeding for the acquirement and enforcement of such liens: such as notice to the owner of the property in certain cases, recording a statement of the lien claimed, making a written demand for payment before proceeding to enforce the lien, commencing proceedings within a limited time, giving notice of the sale, and the like. It is important to observe, that all such requirements of the statute should be strictly complied with, in order that the benefit of the lien thus conferred may be secured, (xx)

(u) Conard v. Atl. Ins. Co. 1 Pet. 386. See also on this subject Dunlevy v. Tal-madge, 32 N. Y. 457; Borman v. Schober, 18 Wis. 437; England v. Lewis, 25 Cal. 337.

(v) Rising v. Granger, I Mass. 48. See also Edwards v, Beaird, Breese (111.), 41.

(w) Act of March 1, 1879, c. 125, § 3, amending U. S. Rev. St. § 3186.

(x) Cross on Liens, 119,129.

(xx) These statutes are very different in the different States, and the numerous cases arising under them generally turn upon local provisions. Among these cases the following will be found instructive. Hopper v. Childs, 43 Pa. 310; Baylies v. Sinex, 21 Ind. 45; Toledo Works v. Bern-heimer, 8 Minn. 118; Felton v. Mi not, 7 Allen, 412; Harsh v. Morgan, I Kansas, 93; Willamette Co. v. Remick, 1 Oreg. 169; McRae v. Creditors, 16 La. An. 305; Tibbetts v. Moore, 23 Cal. 208; Hicks v Branton, 21 Ark. 186; Smith v. Coe, 29 N. Y. 666; Creen v. Fox, 7 Allen, 85; Clark v. Kingsley, 8 Alien, 543; Graves v. Bemia, S