Williamsport National Bank v. Shrey (1992)

Citation: 417 Pa. Super. 563, 612 A.2d 1081 (1992). Court: Superior Court of Pennsylvania. 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/pa-d-c4th/21/cases/0359-01.json, https://static.case.law/pa-super/417/cases/0563-01.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 bank sought a boat subject to its asserted perfected security interest. The owner had requested towing and boat repairs, but the bank had not consented to the repairs. The Superior Court reversed the priority ruling against the repairer. Former 13 Pa.C.S. § 9310 gave the qualifying common-law possessory repair lien priority over a prior security interest, even if perfected, without lender repair consent.

The court distinguished associates-financial-v-odell-pa-1980 as applying the common-law approach, not the UCC rule governing this priority dispute. Its boat was not then required to have a title; do not repeat that historical observation as present boat-title law. It did not decide an auction purchaser’s rights.

Current § 9333 defines the qualifying possessory lien and retains priority absent a contrary express lien statute. 2001 Act 18 enacted revised Division 9, effective July 1, 2001. These current texts are separate from the historical opinion, not a finding that its old section number is current.

Chrysler Credit v. Iguestas, 21 Pa. D. & C.4th 359 (Monroe C.P. 1993), applied Shrey to a car with a title-noted lender and denied that lender’s summary-judgment and sale motions. It is persuasive trial-court treatment. in-re-northrup-pa-1998 also discusses Shrey but expressly reserves the absent lender’s rights. Neither grants a purchaser lien discharge.

Full text, current statute comparison and these actual later applications are verified separately. Comprehensive subsequent treatment, FAA priority and application to pure nonconsensual towing/storage remain needs_verification.

Applies in pennsylvania.

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