| ArizonaAll Arizona rules | You have a lien for labor, parts and storage only if you and the owner agreed on the charges. Once the car has sat unpaid with you for 20 days, you can tell your customer to pay; if they don't within 10 days, you can sell it at public auction after 5 days' notice of the sale. A lender already on the title comes first unless the work was done with its knowledge and consent. The sale route depends on your keeping the car; whether the lien survives letting it go is a question for a lawyer. You can't use the abandoned-vehicle process instead. A.R.S. § 33-1021.01, referenced in 33-1023, is the dry cleaners' lien and does not apply to vehicles. The abandoned-vehicle process in 28-4840 may not be used instead of the 33-1022 lien. | Keep the car“Proprietors of garages and repair and service stations shall have a lien upon motor vehicles of every kind and aircraft, and the parts and accessories placed thereon, for labor, materials, supplies and storage for the amount of the charges, when the amount of the charges is agreed to by the proprietor and the owner.” A.R.S. § 33-1022, azleg.gov text, 2026 session update Keep the car“The lien shall not impair any other lien or conditional sale of record at the time the labor, materials, supplies and storage were commenced to be furnished, unless furnished with the knowledge and consent of the record lienor or vendor.” A.R.S. § 33-1022, azleg.gov text, 2026 session update Sell or title it“when possession of any property described in this article or any other personal property held under lien without provision at law for foreclosure of the lien has continued for twenty days after the charges accrue and remain unpaid, the person holding the property may notify the owner, if in the county where the property is located, to pay the charges.” A.R.S. § 33-1023, azleg.gov text, 2026 session update Sell or title it“Upon failure of the owner within ten days thereafter to pay the charges, the holder of the property may sell it at public auction and apply the proceeds to payment of the charges.” A.R.S. § 33-1023, azleg.gov text, 2026 session update Limit“This section does not impair any lien of a proprietor of a garage or repair or service station under the laws of this state or the right of a lienholder to foreclose, and a proprietor of a garage or repair or service station shall not use this section instead of section 33-1022.” A.R.S. § 28-4840, azleg.gov text, 2026 session update |
| CaliforniaAll California rules | Your lien lasts only as long as you keep the car. Once you let the customer drive it away, the lien is gone and you can no longer sell the car under it. The exception: if you lost the car through trick, fraud or device, getting it back revives the lien, though it ranks behind good-faith interests acquired in the meantime. If the owner approved the work, you also lose the lien unless you apply for lien-sale authorization or file in court within 30 days. An unregistered repair dealer has no lien at all. Vehicles worth $4,000 or less follow Civil Code 3072. An unregistered repair dealer has no lien and cannot charge storage. A returned Declaration of Opposition sends the sale to court. After a sale the owner may redeem within 10 days. | Keep the car“(a) Every person has a lien dependent upon possession for the compensation to which the person is legally entitled for making repairs or performing labor upon, and furnishing supplies or materials for, and for the storage, repair, or safekeeping of, and for the rental of parking space for, any vehicle of a type subject to registration under the Vehicle Code, subject to the limitations set forth in this chapter.” Cal. Civ. Code 3068, effective 1/1/2008 Limit“(a) A person required to have a valid registration under the provisions of this chapter shall not have the benefit of any lien for labor or materials, including the ability to charge storage fees in accordance with applicable laws, or the right to sue on a contract for motor vehicle repairs unless the person possesses a valid registration.” Cal. Bus. & Prof. Code 9884.16, effective 1/1/2024 Sell or title it“Any lien under this section that arises because work or services have been performed on a vehicle with the consent of the registered owner shall be extinguished and no lien sale shall be conducted unless either of the following occurs:
(A) The lienholder applies for an authorization to conduct a lien sale within 30 days after the lien has arisen.
(B) An action in court is filed within 30 days after the lien has arisen.” Cal. Civ. Code 3068, effective 1/1/2008 Sell or title it“A lienholder shall apply to the department for the issuance of an authorization to conduct a lien sale pursuant to this section for any vehicle with a value determined to be over four thousand dollars ($4,000).” Cal. Civ. Code 3071, effective 7/30/2001 Sell or title itFrom a list that begins: “(c) The notice required pursuant to subdivision (b) shall include all of the following statements and information:” “(2) The person has a right to a hearing in court.
(3) If a hearing in court is desired, a Declaration of Opposition form, signed under penalty of perjury, shall be signed and returned to the department within 10 days of the date that the notice required pursuant to subdivision (b) was mailed.” Cal. Civ. Code 3071, effective 7/30/2001 Keep the car“Whenever the possessory lien upon any vehicle is lost through trick, fraud, or device, the repossession of the vehicle by the lienholder revives the possessory lien but any lien so revived is subordinate to any right, title, or interest of any person under any sale, transfer, encumbrance, lien, or other interest acquired or secured in good faith and for value between the time of the loss of possession and the time of repossession.” Cal. Civ. Code 3070, effective 1/1/1995 |
| ColoradoAll Colorado rules | You have a lien for labor and materials, but enforcing it normally takes a court case. You can file to foreclose once the bill is 30 days past due; the lien ends if you haven't filed within 90 days after the charges came due. After judgment, you sell at public auction after 10 days' newspaper notice and a copy to the owner. A separate route skips court when your customer refused to authorize repairs, remove the car or pay: certified letters to the owner and every lender, at least 30 days' wait, then a title application with a surety bond for twice the car's value. No court action is needed for the separate abandoned-vehicle title route (CRS 38-20-116), which applies when the owner refused to authorize repairs, remove the car or pay, and requires a surety bond for twice the vehicle's fair market value. No bond release during a dispute appears in our collection. | Keep the car“Any mechanic or other person who makes, alters, repairs, or bestows labor upon any article of personal property, at the request of the owner of such personal property or his agent shall have a lien upon such property for the amount due for such labor done or material furnished and for all costs incurred in enforcing such lien.” CRS 38-20-106, 2026 edition Sell or title it“(1) If any such charges for which a lien is given by section 38-20-102, 38-20-105, 38-20-106, or 38-20-106.2 or for which a lien is restored by section 38-20-106.5 are not paid within thirty days after the same become due and payable, the mechanic, innkeeper, or other person to whom such lien is given may file a foreclosure action in the county or district court” CRS 38-20-107, 2026 edition Sell or title it“(1) When the lienor has received a judgment and after giving ten days' prior notice of the time and place of such sale, with a description of the property to be sold, by one publication in some newspaper published in the county wherein he or she resides” CRS 38-20-109, 2026 edition Sell or title itFrom a list that begins: “(c) If a repair shop seeks to obtain a certificate of title for an abandoned motor vehicle for purposes of selling such vehicle, a repair shop, or where practicable, its agent, shall:” “(IV) Use the information provided through the Colorado title record search or out-of-state title and lien search to notify by certified mail the owner of record, including an out-of-state owner of record, and all lienholders of its possession of the abandoned motor vehicle.” CRS 38-20-116, 2026 edition Sell or title itFrom a list that begins: “(c) If a repair shop seeks to obtain a certificate of title for an abandoned motor vehicle for purposes of selling such vehicle, a repair shop, or where practicable, its agent, shall:” “(A) Not less than thirty days after the postmarked date of the notice mailed pursuant to subparagraph (IV) of this paragraph (c), present documentation of the requirements specified in subparagraphs (I) to (VI) of this paragraph (c) to the county motor vehicle office in the county in which the repair shop is located and apply for a certificate of title for the abandoned motor vehicle.” CRS 38-20-116, 2026 edition |
| FloridaAll Florida rules | You can hold the car or enforce the lien only if you've substantially complied with Florida's Motor Vehicle Repair Act. To sell, send a notice of lien to the registered owner, your customer and every lender on record within 7 business days after storage charges start and at least 30 days before the sale; no sale can happen sooner than 60 days after the repairs are done. For work under a written estimate, your customer can get the car back by posting a bond with the court clerk; you then have 60 days to sue on it. A shop that has not substantially complied with the Motor Vehicle Repair Act may not hold or enforce a lien (559.919). The bond release under 559.917 covers repair work done under a written repair estimate. | Keep the car“(1) In favor of persons performing labor or services for any other person, upon the personal property of the latter upon which the labor or services is performed, or which is used in the business, occupation, or employment in which the labor or services is performed.” Fla. Stat. 713.58, 2026 edition Limit“No motor vehicle repair shop may refuse to return a customer’s motor vehicle by virtue of any miscellaneous lien, nor may it enforce such a lien in any other fashion if it has failed to substantially comply with the provisions of this part.” Fla. Stat. 559.919, 2026 edition Sell or title itFrom a list that begins: “Such notice must:” “(a) Be sent to the registered owner, the customer, and all other persons claiming an interest therein or lien thereon within 7 business days, excluding Saturday and Sunday, after the date on which storage charges begin to accrue on the vehicle. However, in no event shall the notice of lien be sent less than 30 days before the sale of the motor vehicle.” Fla. Stat. 713.585, 2026 edition Sell or title it“(3) A vehicle may not be sold earlier than 60 days after completion of the repair work. If the date of the sale was not included in the notice of lien required in subsection (1), notice of the sale must be sent by certified mail at least 15 days before the date of sale” Fla. Stat. 713.585, 2026 edition Get it back“(1)(a) A customer or a person of record claiming a lien against a motor vehicle may obtain the release of the motor vehicle from any lien claimed under part II of chapter 713 by a motor vehicle repair shop for repair work performed under a written repair estimate by filing with the clerk of the court in the circuit in which the disputed transaction occurred a cash or surety bond,” Fla. Stat. 559.917, 2026 edition |
| GeorgiaAll Georgia rules | You can keep the car until you're paid, or release it and keep the lien by recording your claim under the title law. Your lien beats other liens except taxes and liens you had notice of before the work. If your customer disputes the bill in writing, start foreclosure within 30 days or lose the lien; every foreclosure must start within a year. Selling takes a court: a foreclosure affidavit, or magistrate court after a certified notice letter sent once the car has sat unpaid 15 to 180 days. During the case, your customer can keep the car by posting a bond. Georgia statute text is from the 2019 official release; confirm it is current. Foreclosure can run under 40-3-54 or through the magistrate court petition in 40-11-19 and 40-11-19.1. | Keep the car“All mechanics of every sort shall have a special lien on any vehicle required to have a certificate of title by Code Section 40-3-20 for work done, or for work done and materials furnished, or for materials furnished in repairing or servicing such vehicle.” O.C.G.A. 40-3-54, 2019 official release (public.resource.org copy) Keep the car“The lien may be asserted by retention of the vehicle, and all contracts for repairs or service to vehicles shall be deemed to incorporate a right of retention by the mechanic to protect this lien until it is paid or satisfied through foreclosure as provided in this Code section.” O.C.G.A. 40-3-54, 2019 official release (public.resource.org copy) Sell or title it“When a motor vehicle has been left with a repair facility for at least 15 days, and no later than 180 days, without payment of amounts owed, the repair facility desiring to file a petition pursuant to Code Section 40-11-19.1 shall send all owners by certified mail the notification letter form developed by the Council of Magistrate Court Judges for such purpose.” O.C.G.A. 40-11-19, 2019 official release (public.resource.org copy) Sell or title it“Not sooner than ten calendar days and not later than six months after compliance with the notice requirements set forth in Code Section 40-11-19, a towing and storage firm, repair facility, or salvage dealer may file an action for a petition to foreclose a lien against the motor vehicle in any magistrate court in the county where the motor vehicle is located.” O.C.G.A. 40-11-19.1, 2019 official release (public.resource.org copy) Get it back“The owner-debtor may retain possession of the vehicle by giving bond and security in the amount determined to be probably due and the costs of the action;” O.C.G.A. 40-3-54, 2019 official release (public.resource.org copy) |
| IllinoisAll Illinois rules | Illinois has two lien laws. For bills of $2,000 or less, the lien lasts until you voluntarily release the car; if it isn't redeemed within 90 days after the work, you can sell it after 30 days' newspaper notice and a certified letter. The general law keeps the lien for a year after the work even if the car leaves, but only if you file a lien notice with the county recorder within 60 days after release. Under the general law a lender recorded before your work comes first, and you can't charge storage until you've sent the lender on the title a certified letter. The bond or deposit release applies only after the shop chooses the sheriff-sale route under 45/6. Liens of $2,000 or less under 770 ILCS 50 also need certified-mail notice 30 days before sale. A collision repair facility that did not follow the Collision Repair Act has no lien for unauthorized parts or labor. | Keep the car“Every person, firm or corporation who has expended labor, skill or materials upon any chattel, or has furnished storage for said chattel, at the request of its owner, reputed owner, or authorized agent of the owner, or lawful possessor thereof, shall have a lien upon such chattel” 770 ILCS 45/1 Keep the car“Every person expending labor, services, skill or material upon or furnishing storage for any chattel at the request of or with the consent of its owner, authorized agent of the owner, or lawful possessor thereof, in the amount of $2,000 or less, shall have a lien upon such chattel” 770 ILCS 50/1 Sell or title it“Unless the chattel is redeemed within 90 days of the completion of the expenditure of such labor, services, skill, or material or furnishing of storage, or within 90 days of the date agreed upon for redemption, the lien may be enforced by a commercially reasonable public or private sale conducted so as to maximize the net proceeds of said sale as hereinafter provided.” 770 ILCS 50/2 Sell or title it“Such sale shall be held only after giving 30 days' notice of the time and place of such sale, by publication once in some newspaper of general circulation” 770 ILCS 50/3 Get it back“any defendant may, in lieu of the bond of surety above provided for, deposit with the sheriff a sum of money equal to the amount of claimant's lien, together with an additional sum of $50, the moneys to be held in lieu of such bond and from which sums claimant's judgment may be paid.” 770 ILCS 45/6 |
| IndianaAll Indiana rules | You have a mechanic's lien for the reasonable value of your work and storage, though the statute doesn't use the words "keep the car." If the bill isn't paid and the car isn't claimed within 30 days after it came in, you can advertise it in the local paper and send certified letters to the owner and every lender on the title naming the auction date. The sale must wait 15 days after both the ad and the letters. The sale route also requires the steps in IC 9-22-1-19, a towing statute; how that applies to a repair shop is a question for a lawyer. IC 9-22-6-2 does not use the words "retain possession." Its sale route cross-references IC 9-22-1-19, a section written for towing services and public agencies; how that applies to a repair shop is a question for counsel. No owner bond release appears for repair shops. | Keep the car“A person that performs labor, furnishes materials or storage, or does repair work on a vehicle at the request of the owner of the vehicle has a mechanic's lien on the vehicle for the reasonable value of the charges for the labor, materials, storage, or repairs.” IC 9-22-6-2, Indiana Code 2026 edition Sell or title itFrom a list that begins: “A person that has a mechanic's lien on a vehicle under subsection (a) or (b) may advertise the vehicle for sale if the person followed the procedures described in IC 9-22-1-19 and if:” “(1) the charges made under subsection (a) or (b) are not paid; and
(2) the vehicle is not claimed;
within thirty (30) days after the date on which the vehicle is left in or comes into the possession of the person for repairs, storage, towing, or the furnishing of materials.” IC 9-22-6-2, Indiana Code 2026 edition Sell or title itFrom a list that begins: “In addition to the advertisement required under subsection (d), the person that holds the mechanic's lien under this section or under IC 9-22-1-21.5(c)” “must notify the owner of the vehicle and any other person that holds a lien of record, as indicated on the certificate of title of the vehicle or discovered as a result of the search described in IC 9-22-1-19, by certified mail, return receipt requested, at the last known address of the owner or person, as applicable, that the vehicle will be sold at public auction on a specified date” IC 9-22-6-2, Indiana Code 2026 edition Sell or title itFrom a list that begins: “A person that holds a mechanic's lien under this section shall execute and deliver to the purchaser of a vehicle under this section or under IC 9-22-1-21.5 a sales certificate in the form designated by the bureau, setting forth the following information:” “Whenever the bureau receives from the purchaser an application for certificate of title accompanied by these items, the bureau shall issue a certificate of title for the vehicle under IC 9-17.” IC 9-22-6-2, Indiana Code 2026 edition |
| MarylandAll Maryland rules | You can keep the car until you're paid. Letting it go doesn't end the lien against your customer, but you can sell only a car you still have. Within 30 days after the lien arises, send every lender on the title a registered or certified letter, or a sale can't recover your storage. After 30 days unpaid, you can sell at public sale with two weekly newspaper notices and a letter 10 days ahead to the owner, lenders and the MVA. A disputing customer can take the car with a corporate bond for double your charge, discharged if you don't sue within six months. Holders of perfected security interests must get notice within 30 days after the lien is created. The owner's corporate bond is discharged if the lienor does not sue within six months. | Keep the car“Any person who, with the consent of the owner, has custody of a motor vehicle and who, at the request of the owner, provides a service to or materials for the motor vehicle, has a lien on the motor vehicle for any charge incurred for any:
(i) Repair or rebuilding;
(ii) Storage; or
(iii) Tires or other parts or accessories.” Md. Code, Com. Law § 16-202, mgaleg.maryland.gov text in effect as of 10/1/2026 Keep the car“The lienor may retain possession of the property subject to the lien until:
(1) The charges which give rise to the lien are paid; or
(2) The lien is otherwise discharged in accordance with this subtitle.” Md. Code, Com. Law § 16-203, mgaleg.maryland.gov text in effect as of 10/1/2026 Sell or title it“If the charges which give rise to a lien are due and unpaid for 30 days and the lienor is in possession of the property subject to the lien, the lienor may sell the property to which the lien attaches at public sale.” Md. Code, Com. Law § 16-207, mgaleg.maryland.gov text in effect as of 10/1/2026 Sell or title it“In addition, the lienor shall send the notice by registered or certified mail at least 10 days before the sale to:
(i) The owner of the property, all holders of perfected security interests in the property and, in the case of a sale of a motor vehicle or mobile home, the Motor Vehicle Administration;” Md. Code, Com. Law § 16-207, mgaleg.maryland.gov text in effect as of 10/1/2026 Get it back“If the owner of property subject to a lien disputes any part of the charge for which the lien is claimed, he immediately may repossess his property by filing a corporate bond for double the amount of the charge claimed.” Md. Code, Com. Law § 16-206, mgaleg.maryland.gov text in effect as of 10/1/2026 |
| MassachusettsAll Massachusetts rules | You have a lien for proper storage and repair charges, but Massachusetts law doesn't expressly say you can hold the car; that's a question for a lawyer. If your customer gets the car by fraud, a trick or a bounced check, the lien stays alive and you can keep enforcing it. To sell, deliver a written demand; if you're not paid within 10 days, you can sue in superior or district court, and the car is sold only if the court orders it. Our collection shows no bond or deposit that lets your customer get the car back during the dispute. Massachusetts law grants the lien but does not expressly say the garage may retain possession. The sale route is court-only (c. 255, §§ 26 and 29). No bond or deposit release appears in our collection. | Keep the car“Persons maintaining public garages for the storage and care of motor vehicles brought to their premises or placed in their care by or with the consent of the owners thereof and persons engaged in performing work upon or in connection with the inspection, reconditioning and repairing of motor vehicles shall have a lien upon such motor vehicles for proper charges due them for the storage, work and care of the same.” M.G.L. c. 255, § 25, General Laws text with amendments passed before 5/31/2026 Keep the car“If the owner of such motor vehicle obtains possession of the same by fraud, trick or by check, draft or order upon any depository or bank which is not honored, the lien on said motor vehicle shall not be deemed to have been discharged and the lien holder may thereafter continue to enforce said lien until the proper charges due him have been paid.” M.G.L. c. 255, § 25, General Laws text with amendments passed before 5/31/2026 Sell or title it“in the case of a lien described in section twenty-four, twenty-five or twenty-five A within ten days, or in other cases within sixty days, after a demand in writing delivered to the debtor or left at his usual place of abode, if within the commonwealth, or mailed postpaid to him at his usual place of abode without the commonwealth, may bring a civil action in the superior court or in a district court” M.G.L. c. 255, § 26, General Laws text with amendments passed before 5/31/2026 Sell or title it“If, upon a default or a trial it is found that a lien exists upon the property and that the property ought to be sold for the satisfaction of the debt, the court may make an order for such sale, determine and record the amount then due and award costs to the prevailing party.” M.G.L. c. 255, § 29, General Laws text with amendments passed before 5/31/2026 |
| MichiganAll Michigan rules | You can keep the car up to 225 days after the last work. Within 105 days of the last work, apply to the Department of State for a certificate of foreclosure, then send certified letters to the owner, every lender and the Bureau of Automotive Regulation; the sale comes at least 75 days after the certificate date. An earlier lender can take the car by paying a capped amount: the lesser of 20% of the repaired car's value or $5,000, or $1,000 for a car worth $5,000 or less. In a dispute, release the car once your customer pays the written estimate plus approved extras. The owner may redeem before the sale. A garage that does not comply with the Motor Vehicle Service and Repair Act cannot use the lien act. A prior lienholder can take the car by paying a capped amount. | Keep the car“Except as otherwise provided in this act, a garage keeper who, in pursuance of a contract that is expressed, implied, written, or unwritten, furnishes labor, material, storage, diagnosis, an estimate of repairs, or supplies for a vehicle, shall have a lien upon the vehicle for the charges due for the storage, maintenance, keeping, diagnosis, estimate of repairs, and repair of the vehicle” MCL 570.303, effective 7/1/2002 Keep the car“The lien attaches to the vehicle on the day the garage keeper performs the last labor or furnishes the last supplies for which a lien is claimed against the vehicle. The garage keeper may keep a vehicle for not more than 225 days after performing the last labor or furnishing the last supplies for which a lien is claimed against the vehicle.” MCL 570.303, effective 7/1/2002 Sell or title it“To enforce a lien under section 3, a garage keeper or authorized agent shall, not more than 105 days after the date the lien attached as provided in section 3, apply to the department, in a format prescribed by the department, for a certificate of foreclosure of garage keeper's lien and bill of sale accompanied by a fee of $10.00 paid to the department.” MCL 570.305, effective 7/1/2002 Sell or title it“After complying with the requirements of subsection (3), the garage keeper shall notify the owner or owners, all lienholders, and the department of state, bureau of automotive regulation, Lansing, Michigan, of the proposed sale of the vehicle in order to satisfy the lien of the garage keeper by a notice sent by certified mail return receipt requested to the last known address of the owner or owners, the lienholders and the bureau.” MCL 570.305, effective 7/1/2002 Get it backFrom a list that begins: “A motor vehicle repair facility that is subject to this act, or a person that is an owner or operator of a motor vehicle repair facility that is subject to this act, shall not, directly or through an agent or employee, do any of the following:” “(d) Fail to return a customer's vehicle if there is a dispute and the customer has paid the amount of the written estimate and any amount in excess of that amount that was agreed to either orally or in writing by the customer.” MCL 257.1307d, effective 4/4/2017 |
| MinnesotaAll Minnesota rules | You can keep the car until your lien is paid; the filing that preserves a lien after you give property back doesn't apply to cars. If the bill is unpaid 90 days after it's due, you can sell at public auction in the county, with notice to your customer at least three weeks ahead and three weekly newspaper notices. Send every lender on the title a certified letter 45 days before your right to sell takes effect, or your lien is ineffective against them. Your customer gets the car back by paying the bill minus unauthorized work and anything over 110% of the approved estimate. Secured creditors on the title must get certified-mail notice 45 days before the right to sell is effective, or the lien is ineffective against them. No title transfer procedure appears in our collection. | Keep the carFrom a list that begins: “Whoever, at the request of the owner or legal possessor of any personal property, shall store or care for or contribute in any of the modes mentioned in section 514.19 to its preservation, care, or to the enhancement of its value,” “shall have a lien upon such property for the price or value of such storage, care, or contribution, and for any legal charges against the same paid by such person to any other person, and the right to retain possession of the property until such lien is lawfully discharged.” Minn. Stat. § 514.18, 2025 edition Keep the carFrom a list that begins: “A lien and right of detainer exists for:” “(4) making, altering or repairing any article, other than livestock, or expending any labor, skill or material on it;” Minn. Stat. § 514.19, 2025 edition Sell or title it“If any sum secured by such lien be not paid within 90 days after it becomes due, the lienholder may sell the property and out of the proceeds of such sale there shall be paid, first, the disbursements aforesaid;” Minn. Stat. § 514.20, 2025 edition Sell or title it“The sale herein provided for shall be made at public auction between nine o'clock in the morning and five o'clock in the afternoon in the county where the property or some part thereof is situated.” Minn. Stat. § 514.21, 2025 edition Get it back“A shop shall return to a customer, upon reasonable demand, the customer's repaired motor vehicle or appliance if the customer pays the shop's bill except the proportion of the bill which represents:
(a) repairs, service calls, or estimates which were performed but not authorized;” Minn. Stat. § 325F.61, 2025 edition |
| MissouriAll Missouri rules | Your lien exists only if your customer's written request stated the maximum repair charge or the daily storage rate, and it ends when you voluntarily give the car back. If the car isn't redeemed within 45 days after the work, you can apply to the Director of Revenue for a lien title, swearing you sent certified notice to the owners and lenders, who can demand a hearing. Within 10 days of getting the lien title, start the sale, with at least 20 days' registered-mail notice to your customer and two newspaper notices. The RSMo 430.040 possession rule belongs to the 430.020 lien, which for repairs needs a written memorandum signed by the owner and is junior to a prior perfected financing statement without the secured party's written consent. | Keep the carFrom a list that begins: “Every person expending labor, services, skill or material upon any motor vehicle or trailer, as defined in chapter 301, vessel, as defined in chapter 306, outboard motor, or aircraft, or part or equipment of an aircraft, at a written request of its owner, authorized agent of the owner, or person in lawful possession thereof,” “shall, where the maximum amount to be charged for labor, services, skill or material has been stated as part of the written request or the daily charge for storage has been stated as part of the written request, have a lien upon the chattel” RSMo 430.082, effective 8/28/2012 Keep the car“No person shall have the right to take any vehicle or aircraft, or part or equipment thereof, or any horse, mule or other animal out of the custody of the person having the lien, except with the consent of the person, or upon paying the amount, lawfully due, for keep, storage, labor or material.” RSMo 430.040, effective 8/28/1983 Sell or title it“If the chattel is not redeemed within forty-five days of the completion of the requested labor, services, skill or material, the lienholder may apply to the director of revenue for a certificate of ownership or certificate of title.” RSMo 430.082, effective 8/28/2012 Sell or title it“Upon receipt of a lien title, the holder shall within ten days begin proceedings to sell the chattel as prescribed in section 430.100.” RSMo 430.082, effective 8/28/2012 Sell or title it“Such sale shall be held only after giving not less than twenty days' notice, first, by mailing a copy of notice, by registered mail, if the address is known, addressed to the owner for whom such expenditure of labor, material, skill or services are performed, in which case a return receipt shall be evidence of due notice;” RSMo 430.100, effective 8/28/1945 |
| MontanaAll Montana rules | Your lien lasts only while you have the car. A lender on the title comes first unless you send it written notice within 30 days of receiving the car; it then has 20 days after mailing to pay your lien and take the car, or your lien moves ahead of its loan. If you're not paid within 30 days after the work, you can file a lien enforcement case; after judgment, the sheriff sells the car at public auction. Your customer can ask for a hearing to contest the sale, and our collection shows no bond to get the car back. The lienholder notice must go to the secured party within 30 days of receiving the vehicle, or the lien is junior to it. The owner may request a hearing to contest the sale. No bond or deposit release appears in our collection. | Keep the car“(2) (a) A person who, while lawfully in possession of an article of personal property, product, or commodity renders any service to the owner or lawful claimant of the article by labor or skill employed for the making, repairing, protection, improvement, safekeeping, carriage, towing, or storage of the article or tows or stores the article as directed under authority of law has a special lien on the article.” MCA 71-3-1201, 2025 edition Lender priority“(1) Subject to subsection (4), the lien created may not take precedence over perfected security interests under the Uniform Commercial Code--Secured Transactions or other recorded liens on the property involved unless, within 30 days from the time of receiving the property, the person desiring to assert a lien upon the property gives notice in writing to the secured party or other lienholder,” MCA 71-3-1202, 2025 edition Sell or title it“If payment for work, labor, or services performed or feed or material furnished is not made within 30 days after the performance of the work, labor, or services or furnishing of the feed or material, the lienor under the provisions of this part may enforce the lien in the following manner:” MCA 71-3-1203, 2025 edition Sell or title it“(b) One copy of the order to show cause provided for in subsection (5)(a) must be served on the owner by certified mail, return receipt requested, and one copy must be served by first-class mail at the owner's last address known to the lienor at least 21 days before the hearing date.” MCA 71-3-1203, 2025 edition Sell or title it“(7) Upon receipt of the court's lien enforcement judgment, the sheriff shall advertise and sell at public auction as much of the property covered by the lien as will satisfy the lien.
(8) The sale must be advertised, conducted, and held in the same manner as prescribed in 25-13-701(1)(b).” MCA 71-3-1203, 2025 edition |
| New JerseyAll New Jersey rules | You can hold the car without going to court until you're paid, and releasing it doesn't end the lien: after demanding payment, you can peacefully take it back anywhere in New Jersey. Send your customer a certified letter saying money is owed; if they don't go to court, you can auction the car 30 days later, after two weekly newspaper notices and 5 days' notice posted at your shop. A lender with an earlier recorded loan comes first. If your customer thinks the bill is too high, they can sue for the car and get it by paying what the court finds due. The lien survives letting the car leave: after demand, the garage keeper may peaceably retake it (N.J.S.A. 2A:44-22). In the 2A:44-23 action the owner offers what he thinks is due and gets the car on paying what the court finds due. | Keep the carFrom a list that begins: “A garage keeper who shall tow, store, maintain, keep, or repair a motor vehicle or furnish gasoline, accessories or other supplies therefor, at the request or with the consent of the owner or the owner's representative” “shall have a lien upon the motor vehicle or any part thereof for the sum due for such towing, storing, maintaining, keeping, or repairing of such motor vehicle or for furnishing gasoline or other fuel, accessories or other supplies therefor, and may, without process of law, detain the same at any time it is lawfully in his possession until the sum is paid.” N.J.S.A. 2A:44-21, text through P.L.2026, c.50 Sell or title it“A motor vehicle is considered detained when the owner or person entitled to possession of the motor vehicle is advised by the garage keeper, by a writing sent by certified mail return receipt requested to the address supplied by the owner or person entitled to possession of the motor vehicle, that goods or services have been supplied or performed, and that there is a sum due for those goods or services.” N.J.S.A. 2A:44-21, text through P.L.2026, c.50 Sell or title it“If no proceedings are taken for the repossession of the motor vehicle or part thereof by the motor vehicle owner or person entitled to possession of the motor vehicle, such property so held by the garage keeper shall, after the expiration of not less than 30 days from the date of the detention, be sold at public auction” N.J.S.A. 2A:44-29, text through P.L.2026, c.50 Sell or title it“Notice of the sale, under section 2A:44-29 of this title shall be published for two weeks at least once in each week, in some newspaper circulating in the municipality in which the garage is situate and not less than five days' notice of such sale shall be given by posting the notice at the garage keeper's place of business.” N.J.S.A. 2A:44-30, text through P.L.2026, c.50 Challenge in court“If upon receiving such statement he considers the amount thereof excessive, he may offer what he considers to be reasonably due and demand possession of the motor vehicle or part thereof so detained. If possession is refused, he may immediately bring an action for possession thereof in the Superior Court, Law Division, Special Civil Part or in any other court.” N.J.S.A. 2A:44-23, text through P.L.2026, c.50 |
| New YorkAll New York rules | You can hold the car until you're paid, but your lien can't exceed your written estimate. If you let the car go more than 30 days after the lien arose, the lien is void against any earlier lender, even if you get the car back. To sell, serve your customer and every lender on the title a notice giving at least 10 days to pay and naming the sale's time and place, then sell at public auction. Within 10 days, your customer can ask a court to rule on the lien; anyone notified can redeem before the sale by paying the lien plus costs. An unregistered repair shop gets no lien. In the Lien Law 201-a proceeding the owner gets the car back only if the court cancels the lien; anyone entitled to notice may redeem before sale by paying the lien and costs (Lien Law 203). | Keep the car“has a lien upon such motor vehicle, motor boat or aircraft for the sum due for such towing, storing, maintaining, keeping or repairing of such motor vehicle, motor boat or aircraft or for furnishing gasoline or other supplies therefor and may detain such motor vehicle, motor boat or aircraft at any time it may be lawfully in his possession until such sum is paid,” N.Y. Lien Law 184, revised 9/22/2014 Keep the car“However, if the bailee of a motor vehicle, motor boat or aircraft has furnished a written estimate of the cost of towing, storage, maintenance, repair or any other service on such motor vehicle, motor boat or aircraft, any lien sought by such bailee for such service may not be in an amount in excess of the written estimate.” N.Y. Lien Law 184, revised 9/22/2014 Sell or title it“It shall also require such owner or any such person to pay the amount of such lien, on or before a day mentioned therein, not less than ten days from the service thereof, and shall state the time when and place where such property will be sold, if such amount is not paid;” N.Y. Lien Law 201, revised 9/22/2014 Sell or title it“Each sale of personal property of a value of one hundred dollars or more, or of any security, to satisfy a lien thereon shall be at public auction to the highest bidder, and shall be held in the city or town where the lien was acquired.” N.Y. Lien Law 202, revised 9/22/2014 Challenge in court“Within ten days after service of the notice of sale, the owner or any person entitled to notice pursuant to section two hundred one of this article may commence a special proceeding to determine the validity of the lien.” N.Y. Lien Law 201-A, revised 9/22/2014 |
| North CarolinaAll North Carolina rules | Your lien starts when you get the car and ends the moment you voluntarily give it back; getting it back later doesn't revive it. It beats every lender on the title. If the bill is unpaid 30 days after it's due, notify the DMV and pay $16.75, or send the DMV-approved certified-mail form yourself; anyone notified has 10 days to ask for a court hearing. Report a car unclaimed 10 days to the DMV within five days, or lose storage for the delay. In a dispute, your customer can sue, pay your lien amount to the court clerk, and get the car released. Owners and others notified have 10 days to request a judicial hearing. A vehicle unclaimed 10 days must be reported to DMV within five days, or storage for the delay is lost. | Keep the car“Any person who repairs, services, tows, or stores motor vehicles in the ordinary course of the person's business pursuant to an express or implied contract with an owner or legal possessor of the motor vehicle, except for a motor vehicle seized pursuant to G.S. 20-28.3, has a lien upon the motor vehicle for reasonable charges for such repairs, servicing, towing, storing,” G.S. 44A-2, ncleg.gov text through S.L. 2026-30 Keep the car“Liens conferred under this Article arise only when the lienor acquires possession of the property and terminate and become unenforceable when the lienor voluntarily relinquishes the possession of the property upon which a lien might be claimed,” G.S. 44A-3, ncleg.gov text through S.L. 2026-30 Sell or title it“If the charges for which the lien is claimed under this Article remain unpaid or unsatisfied for 30 days or, in the case of towing and storage charges on a motor vehicle, 10 days following the maturity of the obligation to pay any such charges, the lienor may enforce the lien by public or private sale as provided in this section.” G.S. 44A-4, ncleg.gov text through S.L. 2026-30 Sell or title it“If the property upon which the lien is claimed is a motor vehicle that is required to be registered, the lienor following the expiration of the relevant time period provided by subsection (a) shall give notice to the Division of Motor Vehicles that a lien is asserted and sale is proposed and shall remit to the Division a fee of sixteen dollars and seventy-five cents ($16.75).” G.S. 44A-4, ncleg.gov text through S.L. 2026-30 Get it back“If in any such action the owner or other party requests immediate possession of the property and pays the amount of the lien asserted into the clerk of the court in which such action is pending, the clerk shall issue an order to the lienor to relinquish possession of the property to the owner or other party.” G.S. 44A-4, ncleg.gov text through S.L. 2026-30 |
| OhioAll Ohio rules | Our Ohio collection has no repair-lien statute; a 2021 Ohio appeals court decision says a repair shop has a common-law lien for the reasonable value of the work, which a Consumer Sales Practices Act estimate violation can defeat. For a car worth under $3,500 left 15 days after the repair, send every owner and lender a notice to remove it by certified mail or another tracked method; if no one claims it in 15 days, the lender's lien is invalid and the clerk of courts issues you a clean title. For costlier cars, see a lawyer. Unregistered shops that must register have no lien. The hold row is a court decision (First District Court of Appeals, 2021), not a statute; it also says a Consumer Sales Practices Act estimate violation can defeat the lien. There is no statutory sale route for vehicles worth $3,500 or more; enforcing the common-law lien goes through court, so take it to counsel. An unregistered shop has no lien (ORC 4775.09). | Limit“(D) No person required to be registered under this chapter shall have the benefit of any lien for labor or materials unless the person is registered under this chapter.” ORC 4775.09, effective 10/6/2026 Court decision“In Ohio, a mechanic who receives a motor vehicle from a consumer for
the purpose of repairing it has a common law lien on the vehicle for the reasonable
value of the labor and materials.” Marreez, 2021-Ohio-4075 (Ohio Ct. App., 1st Dist., decided 11/17/2021) (PDF) Sell or title it“Any repair garage or place of storage in which a motor vehicle with a value of less than three thousand five hundred dollars has been left unclaimed for fifteen days or more following completion of the requested repair or the agreed term of storage shall send a notice to remove the motor vehicle to the last known address of any owner and any lienholder of the motor vehicle.” ORC 4505.101, effective 4/7/2023 Sell or title itFrom a list that begins: “(2) The repair garage or place of storage may obtain a certificate of title to the motor vehicle if all of the following apply:” “(a) The motor vehicle remains unclaimed by any owner or lienholder of the vehicle for fifteen days after the sending of the required notice.” ORC 4505.101, effective 4/7/2023 Sell or title it“(C)(1) The clerk of courts shall issue a certificate of title, free and clear of all liens and encumbrances as follows:
(a) To a repair garage or place of storage that presents an affidavit that complies with all of the requirements of division (A) of this section;” ORC 4505.101, effective 4/7/2023 |
| PennsylvaniaAll Pennsylvania rules | Pennsylvania's repair lien comes from common law, and the 1925 sale law works only while the car is still in your hands. Give your customer written notice of the amount owed; if it isn't paid within 30 days, you can sell the car at public sale on 10 days' notice, given the way a sheriff or constable would. If your customer disputes the bill, they can file a replevin suit within those 30 days, and the dispute is settled in that case. Whether your lien beats a lender that didn't consent to the repairs is a question for a lawyer. 6 P.S. §§ 11-14 (Act 300 of 1925) carries no stated effective date. Whether a common-law lien beats a lender that did not consent to the repairs is a question for counsel; Pennsylvania courts have tied priority to the lender's consent. | Keep the car“where any
person, corporation, firm, or copartnership may have what is
known as a "common law lien" for work done or material furnished
about the repair of any personal property belonging to another
person, corporation, firm, or copartnership,” 6 P.S. §§ 11-14 (Act 300 of 1925), enacted 5/7/1925 Lender priority“A possessory lien on goods has priority over a security interest in the goods unless the lien is created by a statute which expressly provides otherwise.” 13 Pa.C.S. 9333, effective 7/1/2001 Sell or title it“it shall be lawful
for such person, corporation, firm, or copartnership having said
common law lien, while such property is in the hands of the said
person, corporation, firm, or copartnership contributing such
work and material, to give notice in writing to the owner of the
amount of indebtedness for which said common law lien is claimed” 6 P.S. §§ 11-14 (Act 300 of 1925), enacted 5/7/1925 Sell or title it“if said claim is not paid within said thirty days
then the said claimant may sell the said property at public sale
by giving ten days' notice thereof in the same manner as
personal property is sold by sheriff or constable.” 6 P.S. §§ 11-14 (Act 300 of 1925), enacted 5/7/1925 Get it back“Provided, however,
That the owner of said property, if he disputes said bill, may
issue a writ of replevin, as provided by law, within the said
thirty days, and the said dispute shall be settled in said
action of replevin.” 6 P.S. §§ 11-14 (Act 300 of 1925), enacted 5/7/1925 |
| TennesseeAll Tennessee rules | Session-law text amending T.C.A. 66-19-103 (not the codified section) gives you a lien on a car that lawfully comes into your possession, kept until all reasonable charges are paid. After 30 days you can enforce it through the artisans' lien sale procedure, which isn't in our collection; read it first. If you couldn't get written permission to store the car, the 2026 act keeps your lien if you tried in good faith and sent the required notice. Unless licensed under title 55, chapter 17, part 1, you have no lien for repairs over $250 against a seller-lender holding title that didn't authorize them in writing. These rows are session-law text amending T.C.A. 66-19-103, not the codified section. The artisans' lien sale procedure it incorporates (T.C.A. 66-14-102 to 66-14-106) is not in our collection; read it before a sale. | Keep the car“Garagekeepers are entitled to a lien upon all motor vehicles that lawfully come into their possession and are retained in their possession until all reasonable charges due are paid.” Tenn. Public Chapter 1017 (2024), section 5, replacing T.C.A. 66-19-103, effective 7/1/2024 (session-law text) (PDF) Keep the car“A garagekeeper's failure to obtain express written authorization to store a motor vehicle under § 55-31-205(a) does not abrogate the garagekeeper's right to a lien under this section if the garagekeeper makes the good faith attempt to acquire consent and provides notice to the owner under§ 55-31-205(c).” Tenn. Public Chapter 661 (2026), section 2, amending T.C.A. 66-19-103, effective 7/1/2026 (session-law text) (PDF) Sell or title it“A garagekeeper may, after thirty (30) days, enforce such lien in the manner prescribed for the enforcement of artisans' liens under §§ 66-14-102 - 66-14-106; except, that the garagekeeper:” Tenn. Public Chapter 1017 (2024), section 5, replacing T.C.A. 66-19-103, effective 7/1/2024 (session-law text) (PDF) Limit“A person, firm, or entity, unless licensed and regulated under title 55, chapter 17, part 1, does not have a right to a lien against a lienor, who is also the seller of such motor vehicle or who retains title under a title retention or conditional sale agreement, for repairs in excess of two hundred fifty dollars ($250) made on such motor vehicle, unless the person, firm, or entity making the repairs has received a written authorization from the lienor or seller to make such repairs on the motor vehicle.” Tenn. Public Chapter 1017 (2024), section 5, replacing T.C.A. 66-19-103, effective 7/1/2024 (session-law text) (PDF) |
| TexasAll Texas rules | You can keep the car until you're paid; giving it back releases the lien unless the check or card you took bounced or was stopped. To sell, send the owner and every lender on the title a certified letter stating the amount and asking for payment, and within 30 days after the charges accrue file a copy, with a $25 fee, with the county tax assessor-collector. If you're still unpaid by the 31st day after filing, you can sell at public sale. Your lender letter must include your shop's address, legal name, tax ID and signed work order, or the lender's lien comes first. The garageman's lien in 70.003(c) covers care and towing and excludes repair charges. The owner or a lienholder may pay all charges before the 31st day after the county filing to get the vehicle. No bond release appears in our collection. | Keep the car“(a) A worker in this state who by labor repairs an article, including a vehicle, motorboat, vessel, or outboard motor, may retain possession of the article until:
(1) the amount due under the contract for the repairs is paid; or
(2) if no amount is specified by contract, the reasonable and usual compensation is paid.” Tex. Prop. Code 70.001, effective 6/19/2015 Storage lien“(c) A garageman with whom a motor vehicle, motorboat, vessel, or outboard motor is left for care has a lien on the motor vehicle, motorboat, vessel, or outboard motor for the amount of the charges for the care, including reasonable charges for towing the motor vehicle, motorboat, vessel, or outboard motor to the garageman's place of business and excluding charges for repairs.” Tex. Prop. Code 70.003, effective 9/1/2009 Sell or title it“Subject to Subsection (a-1), a holder of a possessory lien on a motor vehicle under Section 70.001, other than a person licensed as a franchised dealer under Chapter 2301, Occupations Code, shall file a copy of the notice and all information required by this section with the county tax assessor-collector's office in the county in which the repairs were made with an administrative fee of $25 payable to the county tax assessor-collector.” Tex. Prop. Code 70.006, effective 9/1/2021 Sell or title it“(b) Except as provided by Subsection (c), the notice must be sent by certified mail with return receipt requested and must include the amount of the charges and a request for payment.” Tex. Prop. Code 70.006, effective 9/1/2021 Sell or title it“(f) If the charges are not paid before the 31st day after the date that a copy of the notice required by Subsection (a) is filed with the county tax assessor-collector's office, the lienholder may sell the motor vehicle, motorboat, vessel, or outboard motor at a public sale and apply the proceeds to the charges.” Tex. Prop. Code 70.006, effective 9/1/2021 |
| VirginiaAll Virginia rules | You can keep the car until you're paid, but if the title shows a lender, your lien is capped at $1,000, plus a claim on anything left after the lender is paid. Check the title with the DMV within seven business days after the invoice is due; once it's 10 days past due, you can enforce. For a car worth $12,500 or less, sell at public auction after notifying the DMV ($40), which gives the owner and lender 15 days to reclaim it; a costlier car needs a court petition. Your customer can get the car back by suing you and posting a bond. The repair lien is capped at $1,000 when the title shows a lien. Vehicles worth more than $12,500 need a court petition. The mechanic must check the title for liens within seven business days after the invoice is due. | Keep the car“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.” Va. Code § 46.2-644.02 Keep the car“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.” Va. Code § 46.2-644.01 Sell or title it“Any bailee eligible to enforce a lien under § 46.2-644.01 or 46.2-644.02, if the value of the vehicle affected by the lien does not exceed $12,500, may sell such vehicle by public auction, for cash, in accordance with the provisions of this section.” Va. Code § 46.2-644.03, effective 7/1/2026 Sell or title it“If the Department confirms owner or lienholder information, the Department shall notify the owner, at the last known address of record, and any lienholder, at the last known address of record, of the intent to sell the vehicle, by certified mail, return receipt requested, and advise them to reclaim the vehicle and repay the debt owed within 15 days from the date the notice was sent.” Va. Code § 46.2-644.03, effective 7/1/2026 Get it back“If the owner of the vehicle held by the mechanic shall desire to obtain possession thereof, he shall make the mechanic defendant in proceeding in the county or municipal court to recover the vehicle.
The owner may give a bond payable to the court, in a penalty of the amount equal to the lien claimed by the mechanic and court costs” Va. Code § 46.2-644.02 |
| WashingtonAll Washington rules | No Washington statute in our collection expressly lets you hold the car until paid; that's a question for a lawyer. Your lien survives releasing the car if you file a lien notice with the county auditor within 90 days after delivery, and it ends unless you enforce it, in court or by notice and sale, within nine months after filing. A lender recorded before your work stays ahead of you, your customer can redeem by paying everything before the sale, and you have no lien for work you didn't get authorized as the estimate law requires. No Washington statute in our collection expressly lets a repair shop keep the car until paid; whether a common-law possessory lien applies is a question for counsel. A shop that skipped the required estimate and authorization steps has no lien for the unauthorized work (RCW 46.71.041). Title through the lien process needs the county auditor filing and an affidavit of sale (RCW 60.08.085). | Keep the car“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:” RCW 60.08.010 Limit“A repair facility that fails to comply with RCW 46.71.021, 46.71.025, or 46.71.031 is barred from asserting a possessory or chattel lien for the amount of the unauthorized parts or labor upon the motor vehicle or component.” RCW 46.71.041 Sell or title it“Unless collateral is perishable or threatens to decline speedily in value or is of a type customarily sold on a recognized market, reasonable notification of the time and place of any public sale or reasonable notification of the time after which any private sale or other intended disposition is to be made shall be sent by the lienholder to the lien debtor, by first-class mail, and registered or certified mail,” RCW 60.10.030 Sell or title it“The department of licensing, and the department's agents and subagents, shall not transfer title of a vehicle through the chattel lien process under this chapter and chapter 60.10 RCW unless an affidavit of sale and the following documentation is submitted: (1) A certified copy of the lien filing that is filed with the county auditor;” RCW 60.08.085 Get it back“At any time before the lienholder has disposed of collateral or entered into a contract for its disposition under this chapter, the lien debtor or any other secured party may redeem the collateral by tendering fulfillment of all obligations to the holder that are secured by the collateral” RCW 60.10.050 |
