Welded Tube Co. of America v. Phoenix Steel Corp. (1975)

Citation: 512 F.2d 342 (3d Cir. 1975). Court: United States Court of Appeals for the Third Circuit. Full judicial opinion retrieved October 17, 2026. The Caselaw Access Project file is an unofficial complete reporter reproduction.

Source note (2026-10-18):

• Links on this page to https://static.case.law/f2d/512/cases/0342-01.json, https://static.case.law/pa/370/cases/0213-01.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.

A tubing manufacturer retained its customer’s steel coils for asserted processing and storage charges and purchased them itself at a purported public auction under the 1925 artisan-sale act. The Third Circuit upheld the conclusions that the credit-delivery contract waived the asserted artisan lien, no storage lien arose merely from artisan possession, and refusal to return the coils constituted conversion.

The court remanded for fair-market-value findings and clarification of a separate pretermination storage compensation claim; it otherwise affirmed. Conversion arose on the earlier refusal to relinquish the steel, not only on the later auction. The opinion does not adjudicate the title of an independent good-faith purchaser.

The court distinguished the contract in International Electronics v. N.S.T. Metal Products, 370 Pa. 213 (1952), where contract terms preserved possession and did not establish lien waiver as a matter of law. Thus credit terms must be read in their actual contractual context.

in-re-northrup-pa-1998 later quotes Welded Tube’s storage-lien limitation. That actual treatment and the complete opinion body are verified, but comprehensive subsequent history/current application remains needs_verification. This is evidence of a real conversion remedy, not a universal auction purchaser safe-harbor rule.

Applies in pennsylvania.

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