Pruitt v. LGR Trucking (2002)
Decided February 22, 2002; Hamilton County No. C-010405. Complete official eight-page opinion retrieved 2026-10-17.
Facts and holding
A boat repairman lawfully retained an unpaid customer’s boat, then auctioned it while collection litigation continued. He attempted to use former R.C. 4585.31’s unpermitted-watercraft process, but gave only five days of its then-required notice.
The court held the sale unlawful: a right to retain the boat was not a right to dispose of it (¶¶8–12). The owner received conversion damages measured by the boat’s value, credited against the repair debt. Because that credit supplied the recoverable damages, judgment was affirmed despite the trial court’s incorrect characterization of the sale (¶¶7, 13–17).
Reasoning and practical limits
The repairman could not simultaneously retain the boat under a lawful lien and claim it remained on his premises without permission. Substantial-compliance and relocation arguments did not excuse the statutory defects. The court found no basis for punitive damages on that record.
The case adjudicated the repairman/owner debt and conversion claims. It did not decide an innocent third-party buyer’s title or every lender’s survival rights.
Current statutory fit and later treatment
The historical six-month and forty-five-day provisions described in the opinion are not current R.C. 1547.305, whose twenty-day/ten-day title alternative requires lack of permission and absence of a valid repair/storage contract. The relevant lien/court-sale provisions remain in ch. 4585; the bailee statute’s other-procedure exclusion is in 1333.41(E). No old deadline is imported into the current routes.
Focused public research did not establish comprehensive subsequent appellate history or later merits treatment. These remain needs_verification; no unqualified good-law certification is made.
Applies in →
ohio · vessels · marina-and-storage-lien-sales-of-vessels
Disclaimer. Legal information, not legal advice. Read the full opinion and current law; later authority may limit this decision.