Artisan's and Service Liens

"Every innkeeper and the keeper of a boardinghouse or house of private entertainment shall have a lien upon, and may retain possession of, the baggage and other property of his guest or boarder brought upon his premises, and also upon the property of the employer of such guest or boarder, controlled and brought upon the premises by such guest or boarder in the course of his employment, for the proper charges due from such guest for his board and lodging. (Va. Code Ann § 43-31)

A. Every keeper of a livery stable, hangar, tie-down, or marina, and every person pasturing or keeping any horses or other animals, boats, aircraft, or harness, shall have a lien upon such horses and other animals, boats, aircraft, and harness, for the amount that may be due him for the towing, storage, recovery, keeping, supporting, and care thereof, until such amount is paid. (Va. Code Ann § 43-32)

Every mechanic who shall alter or repair any article of personal property at the request of the owner of such property shall have a lien thereon for his just and reasonable charges therefor and may retain possession of such property until such charges are paid. (Va. Code Ann § 43-33)

B. Every keeper of vehicles shall have a lien upon such vehicles for the amount that may be due him for the towing, storage, recovery, and care thereof, until such amount is paid. In the case of a tow truck driver or towing and recovery operator furnishing services to a truck, tractor truck, or combination of vehicles, any such lien held shall apply to any power unit, tractor, trailer, or semitrailer in the combination. (Va. Code Ann § 46.2-644.01)

A. Every mechanic who shall alter or repair any vehicle at the request of the owner or authorized person in possession of such vehicle shall have a lien thereon for his just and reasonable charges therefor and may retain possession of such property until such charges are paid. Such lien shall be in addition to any lien under § 46.2-644.01.

B. No lien under this section shall exceed $1,000 for any vehicle for which the title shows an existing lien. However, the mechanic shall be entitled to a lien against the proceeds, if any, remaining after the satisfaction of all prior security interests or liens. (Va. Code Ann § 46.2-644.02)

(1) A warehouseman has a lien against the bailor on the goods covered by a warehouse receipt or storage agreement or on the proceeds thereof in his possession for charges for storage or transportation (including demurrage and terminal charges), insurance, labor, or other charges, present or future, in relation to the goods, and for expenses necessary for preservation of the goods or reasonably incurred in their sale pursuant to law. If the person on whose account the goods are held is liable for like charges or expenses in relation to other goods whenever deposited and it is stated in the warehouse receipt or storage agreement that a lien is claimed for charges and expenses in relation to other goods, the warehouseman also has a lien against the goods covered by the warehouse receipt or storage agreement or on the proceeds thereof in his possession for such charges and expenses whether or not the other goods have been delivered by the warehouseman. But against a person to whom a negotiable warehouse receipt is duly negotiated a warehouseman's lien is limited to charges in an amount or at a rate specified on the receipt or if no charges are so specified then to a reasonable charge for storage of the goods covered by the receipt subsequent to the date of the receipt. (Va. Code Ann § 8.7-209)

Comment: While partly reflecting an historical vestige, this is still the operative Virginia Code provision dealing with storage liens on boats and airplanes. Boats are titled and registered through the Virginia Department of Game and Inland Fisheries. Va. Code Ann. §§ 29.1-700, et seq. Comment: Motor vehicles are titled through the Virginia Department of Motor Vehicles. Va. Code Ann. §§ 46.2-600, et seq.