Chattel Liens

"Every person, firm or corporation who shall have performed labor or furnished material in the construction or repair of any chattel at the request of its owner, shall have a lien upon such chattel for such labor performed or material furnished, notwithstanding the fact that such chattel be surrendered to the owner thereof: PROVIDED, HOWEVER, That no such lien shall continue, after the delivery of such chattel to its owner, as against the rights of third persons who, prior to the filing of the lien notice as hereinafter provided for, may have acquired the title to such chattel in good faith, for value and without actual notice of the lien. (RCW 60.08.010)

(a) ""Possessory lien."" In this section, ""possessory lien"" means an interest, other than a security interest or an agricultural lien:
(1) Which secures payment or performance of an obligation for services or materials furnished with respect to goods by a person in the ordinary course of the person's business;
(2) Which is created by statute or rule of law in favor of the person; and
(3) Whose effectiveness depends on the person's possession of the goods.
(b) Priority of possessory lien. A possessory lien on goods has priority over a security interest in the goods only if the lien is created by a statute that expressly so provides.
(c) A preparer lien or processor lien properly created pursuant to chapter 60.13 RCW or a depositor's lien created pursuant to chapter 22.09 RCW takes priority over any perfected or unperfected security interest. (RCW 62A.9A-333)"

"The chattel lien statute applies most often in the context of auto-repair. Chattel lien holders can perfect their liens through possession or the filing of a lien notice. Id. If the lien notice option is exercised, the chattel lien holder must file its notice within 90 days of delivery of the chattel to the debtor. Id.; Burns v. Miller, 107 Wn.2d 778, 782, 714 P.2d 1190 (1987).

A prior perfected security interest or leasehold interest prevails over a chattel lien in the same collateral. Ibrahim v. HAPO Federal Employees Credit Union, 28 Wn.App. 597, 625 P.2d 176 (1981)."