Welcome Home Center, Inc. v. Central Chevrolet Co., Inc. (1978)

Citation: 272 S.C. 166, 249 S.E.2d 896 · Court: Supreme Court of South Carolina · Decided: December 5, 1978 · Opinion No.: 20829 · Author: Ness, J.; Lewis, C.J., Littlejohn, Rhodes and Gregory, JJ., concurred.

Source note (2026-10-18):

• Links on this page to https://static.case.law/sc/272/cases/0166-01.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.

The complete opinion was retrieved from the Caselaw Access Project’s unofficial verbatim primary-opinion copy at the source URL on 2026-10-17. Raw JSON, retrieval metadata and checksum are retained with the South Carolina independent review.

Facts

Welcome Home Center brought its vehicle to Central Chevrolet for service and tendered payment for the current work. The garage demanded payment for earlier work on the same vehicle as well and refused to release it when that additional payment was refused. The earlier work had been followed by voluntary release of the vehicle. The trial court granted the owner summary judgment.

Holding

Affirmed. Both the repair-lien statute and common law conditioned this lien on continuous possession. The prior lien expired when the garage voluntarily released the vehicle; later custody did not revive it for the earlier debt.

Reasoning

The court read the continuous-possession requirement in then-current § 29-15-10 with artisan-lien rules, citing Clark Bros. & Co. v. Pou and Bouknight v. Headden. Release and extension of credit destroy the possessory lien. An unpaid personal debt does not become a surviving lien merely because the same vehicle returns to the shop.

Practical impact

A purchaser or officer relying on § 29-15-10 should examine the possession history and identify which work generated the claim. This case concerns the existence of a repair lien; it does not decide every priority contest, storage charge, or purchaser’s title after a completed defective auction.

Good-law status

The still_good value is limited to the continuous-possession holding. The independently retrieved current § 29-15-10(A)(2) retains that condition. The online statute is the legislature’s unofficial compilation through 2025; the independent review also searched 2026 enacted texts.

The Attorney General’s November 6, 1998 opinion was retrieved in full and applies Welcome Home Center in discussing continuous possession and attempted transfer of a garage lien. That is advisory subsequent application, not appellate affirmance or complete citator clearance. The full holding was verified; exhaustive later judicial treatment is not certified.

Applies in →

south-carolina

Legal information, not legal advice. Verify the opinion, current statutes and subsequent treatment before acting. Holding verified: 2026-10-17.