Ark. Code Ann. § 18-45-201 (2026)
Right to absolute lien
All blacksmiths, horseshoers, wheelwrights, automobile repairmen, airplane repairmen, machine shops, farm implement repairmen, automotive storagemen, firms, and corporations who perform, or have performed, work or labor for any person, firm, or corporation, who have furnished any materials or parts for the repair of any vehicle or farm implement, including tires and all other motor accessories and bodies for automobiles, trucks, tractors, airplanes, and all other motor propelling conveyances, or who store on their premises any automobile, truck, tractor, airplane, or other automotive vehicle, if unpaid, shall have an absolute lien upon the product or object of their labor, repair, or storage and upon all wagons, carriages, automobiles, trucks, tractors, airplanes, farm implements, and other articles repaired or stored and all horses or other animals shod by them, for the sums of money due for their work, labor, storage, and for materials furnished by them and used in the product, the shoeing and repairing, including the furnishing of tires and all other accessories and bodies for automobiles, trucks, tractors, airplanes, and all other motor-propelled vehicles.
History. Acts 1919, No. 140, § 1, p. 123; C. & M. Dig., § 6866; Pope's Dig., § 8822; Acts 1963, No. 159, § 1; 1965, No. 458, § 1; A.S.A. 1947, § 51-404.
Cross References. Liens for motor vehicle storage, § 18-48-401 et seq.
Liens on animals, §§ 18-48-101 et seq., 18-48-201 et seq., 18-48-301 et seq.
Research References
Ark. L. Notes.
Brill, Equity and the Restitutionary Remedies: Constructive Trust, Equitable Lien, and Subrogation, 1992 Ark. L. Notes 1.
Case Notes
Constitutionality.
Due to the distinction between private parties who utilize overt assistance from state officials and private parties who do not make use of state officials when relying on statutory remedies for settling a dispute, repairmen's lien laws are not unconstitutional for violating federal due process requirements. Leonards v. E.A. Martin Mach. Co., 321 Ark. 239, 900 S.W.2d 546 (1995).
Bona Fide Purchasers.
Where at the commencement of the debtors' bankruptcy case, auto repairman's lien was perfected by his possession of the vehicle, the lien could not be avoided by the debtors. As long as the vehicle remained in the possession of the repairman, there could be no bona fide purchaser; any potential purchaser at the commencement of the case could not have obtained the vehicle without the repairman relinquishing possession and asserting his lien. Scott v. Becker, 88 B.R. 196 (Bankr. E.D. Ark. 1988).
Common Law Lien.
The right to a common law lien for a mechanic repairing an automobile has been superseded. Bond v. Dudley, 244 Ark. 568, 426 S.W.2d 780 (1968).
Nonpayment.
Negligent termination of a bailment of automobile left for repairs by bailee, who was not obligated to terminate the bailment because of nonpayment, could result in liability for injuries suffered when a person to whom the bailor subsequently loaned the vehicle ran into plaintiff. Murray ex rel. Murray v. Whit Tatum Motors, Inc., 673 F. Supp. 981 (W.D. Ark. 1987).
Possession.
Failure of an automobile repairman to surrender a car upon refusal of the owner to pay or tender charges for repairs did not constitute conversion. Beloate v. Carruthers Motor Co., 168 Ark. 245, 269 S.W. 573 (1925).
The repairman has no right to retain possession of the car against the demand for possession of the vendor under a conditional sale contract, the purchase money not having been fully paid. Corning Motor Co. v. White, 173 Ark. 144, 293 S.W. 46 (1927).
In an owner's action seeking recovery of an all-terrain vehicle (ATV), a monetary award in favor of a wrecker service was erroneous because the wrecker service's liens under this section and § 18-48-402 were satisfied upon receipt of the sum generated from the sale of the ATV and its lack of perfection of its lien under § 27-50-1208 precluded a finding of a possessory lien. Payne v. Donaldson, 2010 Ark. App. 255, 379 S.W.3d 22 (2010).
Property Subject to Lien.
Welder who built model cutter and attached it to mower-tractor did not have a lien on the mower-tractor for cost of model cutter. Strange v. Corley, 221 Ark. 316, 253 S.W.2d 337 (1952).
Wheelwrights.
Former similar statute in providing for the enforcement of wheelwright's liens covered the whole subject and § 18-45-101 was not applicable to wheelwright's liens. Shelton v. Little Rock Auto Co., 103 Ark. 142, 146 S.W. 129 (1912) (decision under prior law).
Cited: Terrell v. Loomis, 218 Ark. 296, 235 S.W.2d 961 (1951); J.I. Case Co. v. Seabaugh, 10 Ark. App. 186, 662 S.W.2d 193 (1983); Herringer v. Mercantile Bank, 315 Ark. 218, 866 S.W.2d 390 (1993).