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.json are 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 →

virginia · aircraft

Legal information, not legal advice. Verify current law and subsequent treatment before relying on this historical circuit-court decision.