Stanfield Body Shop v. Bruner (2022)
Rendered August 19, 2022, Maze, J.; Jones and McNeill concurred. Not to be published. The full ten-page court opinion, not the publisher’s AI-assisted summary, was read through the reader. The direct origin request returned 403; no origin-byte digest is claimed.
Facts and procedure
The owner sought an estimate for his damaged truck. The shop secured it to a frame rack, removed its bumper, and used specialized measuring equipment. The owner declined the quoted repairs. The shop charged USD 300 for the assessment and USD 35 daily storage and detained the truck. The trial court treated the assessment as outside lienable work, limited storage fees, found conversion, and awarded the owner related expenses.
Complete holdings and disposition
- CR 52.01 substantial-evidence review governs the bench findings; legal conclusions receive de novo review. Credibility and evidence weight remain for the fact finder.
- Actual diagnostic labor was work done under KRS 376.270. Storage was independently lienable. Either supported the lien; the shop was entitled to detain the truck until payment of reasonable or agreed charges, so the owner’s immediate right to return—an essential conversion element—was absent. The contrary conversion judgment was vacated, with instructions to dismiss that claim.
- central-trust-v-dans-marina-1993 excludes profit-enhancing service charges, not genuine inspection labor. airrich-v-fortener-aviation-2016 supported lienable inspection work.
- The court upheld the USD 300 assessment award. It also upheld the trial court’s authority to determine reasonable storage rather than automatically award more than 500 days of claimed fees exceeding the truck’s value. Lawful detention did not make unlimited accrual reasonable; filing after release was an available means to preserve the lien.
- Because the trial court wrongly assumed no right to detain after November 28, 2018, a new evidentiary hearing and findings were required on how much additional storage was reasonable. The court did not fix that amount or hold that every later day necessarily earned no fee.
Affirmed in part, vacated in part, and remanded, opinion pp. 5–9. No lien auction occurred; this decision neither decides statutory sale surplus nor gives a purchaser universal clean title.
Treatment and current boundary
The opinion supplies positive, specifically identified treatment of Central Trust and Airrich. Its unpublished status is preserved rather than presented as a binding reported precedent. Current 376.270 was compared; modern tow-specific charges/notices have their separate statutory regime. No exhaustive subsequent-treatment search or comprehensive good-law certificate is claimed.
See kentucky, motor-vehicles.
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