Griffin v. Teague (2005)
The court affirmed summary judgment for a storage facility using then § 91. It did not hold that a storage contract automatically transfers title or that today’s storage seller can elect around the self-storage Act. Decided April 19, 2005; parallel citation 2005 OK CIV APP 40. Full reporter-derived judicial opinion retrieved from Caselaw Access Project, an unofficial delivery.
Source note (2026-10-18):
- Links on this page to
https://static.case.law/p2d/610/cases/1222-01.json,https://static.case.law/p3d/115/cases/0899-01.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.
Facts and procedure
After eleven months of default, Hop & Loc sold unit K44 contents. Griffin sought conversion/unjust-enrichment damages and summary judgment, alleging defects under the self-storage Act. The facility cross-moved, invoking contract and alternative § 91 lien. The trial court denied Griffin’s motion and granted facility summary judgment. His address changed without notice to the facility. Opinion ¶¶ 1–11, 18–20.
Holdings and reasoning
Then §§ 199/197(N) preserved other liens. The contract left possession with occupant until default and did not create the Act’s entry-date lien or assign title. On taking possession after default the facility became bailee with a § 91 service lien; contract terms alone were insufficient, and the sale still required compliance with that remedy. Opinion ¶¶ 2–8.
January 17 mailed/posted notice scheduled February 3 sale, identified Griffin, unit contents, services, charges, time/place and foreclosing party, and met then accrual/ten-day rules. Identified unit-contents description substantially complied without prejudice; liberal construction of enforcement followed established entitlement. Mailing to supplied last-known address satisfied the duty; the court would not add another mailing. Citing federal self-help/state-action doctrine, it rejected the constitutional actual-notice challenge on these facts. Undisputed facts supported facility summary judgment; Taylor and Goodman concurred. Opinion ¶¶ 9–24.
Treatment and current use
The court relies on Security National Bank v. Reiginger, 1980 OK 70, 610 P.2d 1222, whose full text was retrieved for its earlier priority/notice reasoning. Reiginger.
Current §§ 91(A)(1)(c)/91A(A)(1)(c) expressly select the remedy: untitled goods not required to be titled and covered by the storage Act use that Act; covered titled property uses applicable service-lien procedure. Current § 197 adds known-lender notice, verified-mail/email predicates and buyer/surplus rules. Griffin therefore does not permit evading later statutory selection. SB1326’s November 1, 2026 agreement/abandonment changes do not create such an election. Current Title 42; SB1326.
Full holding and identified statutory qualification are verified. No comprehensive citator certificate or later merits-outcome search is claimed.
Applies in oklahoma and towing-storage-and-mechanics-lien-sales.
Legal information, not legal advice. Verify current statutes, notice facts and subsequent treatment before relying on this historical decision.