Ally Financial Inc. v. Pira

Plaintiff, to whom dealer had assigned interest in installment contract with purchaser of 2013 vehicle, filed complaint for replevin seeking possession of vehicle. Defendant asserted affirmative defense that he had a common-law possessory lien, for cost of work (detailing and repairs) performed on vehicle and for storage fees that accrued after work completed. Court properly found that Defendant's lien covered only charges relating to work performed on vehicle. The artisan's common-law lien covers only "reasona ble charges" for work that imparted added value to goods in question, regardless of whether owner and artisan contract for storage of goods after completion of artisan's work.(HUDSON and SPENCE, concurring.)