Gold Key Aviation v. International Jet Charter (2001)
Facts and holding
Source note (2026-10-18):
- Links on this page to
https://static.case.law/va-cir/56/cases/0421-01.jsonare an (unofficial Caselaw Access Project copy, retrieved before 2026-10-18; host disallows automated access); no official or otherwise permitted full-text copy was located on 2026-10-18.
After an aircraft-management relationship ended, the owner recovered the aircraft and challenged the manager’s lien. The circuit court treated the manager as a keeper, rejected a mandatory-continuing-possession reading of § 43-32, and held former § 55-100 displaced § 43-34.1’s additional SCC recordation requirement for the FAA-recorded claim. Full opinion, Caselaw Access Project reproduction (unofficial).
Reasoning and practical limit
The court distinguished total charges from limited priority against secured debt and applied the aircraft-recordation statute notwithstanding contrary state recordation provisions. It adjudicated lien validity, not a completed foreclosure sale or universal purchaser discharge. Its historical USD 300/625 figures are not today’s statutory amounts. Opinion.
Currentness and later treatment
Current § 55.1-409 retains the aircraft-recordation language; § 43-34.1 still
prints both filing locations. Current recordation text;
current lien text.
This is circuit-court authority. Comprehensive later appellate treatment remains
needs_verification. The full text was retrieved on October 18, 2026 from the
Caselaw Access Project’s verbatim reproduction of 56 Va. Cir. 421 (unofficial,
labelled); it replaces the earlier commercial-reader copy. The court also held that
§ 43-34.1’s lien is enforceable once filed as former § 55-100 allowed; it did not
describe how that nonpossessory lien is foreclosed. No still_good inference is made.
Applies in →
Legal information, not legal advice. Verify current law and subsequent treatment before relying on this historical circuit-court decision.