Dover Federal Credit Union v. Liberto (2003)
Full caption: Dover Federal Credit Union v. Anthony Liberto t/a Liberto Mini-Storage. Docket: 02-11-0151 · Judge: Trader · Submitted and decided: April 2, 2003.
Facts
The credit union’s lien on a vehicle was recorded at DMV in August 1999. The debtor later placed the vehicle at Liberto’s self-storage facility and defaulted on both the loan and storage rent. The lender sought replevin; the operator sought payment of storage charges before releasing the car. The case was decided on stipulated facts. Source: full official four-page decision, retrieved/read 2026-10-17.
Holding and reasoning
Under 25 Del. C. § 4903, the recorded motor-vehicle security interest prevailed over the self-storage lien. The lender received a writ of replevin. The operator’s storage counterclaim and quantum-meruit claim against the lender failed; the lender had not requested the service. The lender’s attorney-fee demand was also denied without an applicable contract or statutory basis. Source: full opinion above.
Limits and later treatment
This applies the self-service storage act, not the distinct ch. 39 garagekeeper lien. There was no adjudicated auction buyer or ruling that every defective storage auction is void. The current titled-motor-vehicle exception appears in the full statute: https://delcode.delaware.gov/title25/c049/index.html. No comprehensive citator or later dispositive decision was established in the independent review; no “still_good” status is inferred from the absence of a search hit.
Bounded final review (2026-10-18)
Re-read 2026-10-18 from courts.delaware.gov (id 29970): 25 Del. C. § 4903 makes a lien secured by a motor-vehicle title superior to the storage lien, so the credit union received possession and a writ of replevin; the storage operator’s counterclaim and the credit union’s fee claim were denied. Comprehensive later treatment remains needs_verification; no citator certification is made.
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Legal information, not legal advice. Verify against the current primary source before relying on this summary.