Allstate Lien and Recovery Corporation v. Stansbury (2015)

Court: Court of Appeals of Maryland · Decided: November 23, 2015 · Opinion: Battaglia, J.; Harrell, J., concurred.

Facts

A garage and lien processor demanded an additional USD 1,000 processing fee before the owner could redeem his repaired car. The vehicle was subsequently sold.

Holding

The statutory repair lien did not include that pre-sale enforcement fee. The Court affirmed the intermediate appellate judgment.

Reasoning

Section 16-202(c) lists the lien’s secured charges. Sale-expense recovery and judicial review under §§16-206 to 16-208 did not authorize unilateral enlargement of the redemption lien.

Practical impact

Review the debt underlying a proposed lien sale. The Court expressly left completed-sale validity outside the question presented. See maryland.

Good-law status

needs_verification; comprehensive later treatment was not established.

Sources

Legal information, not legal advice. Verify current law and later treatment before relying on this decision.