Cal. Codes » Civil Code / DIVISION 3. OBLIGATIONS / PART 4. OBLIGATIONS ARISING FROM PARTICULAR TRANSACTIONS / TITLE 14. LIEN / CHAPTER 6.5. Liens on Vehicles
California Codes

Cal. Civil Code § 3068.1 (2026)

✓ current as of May 2026
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(a)(1)Every person has a lien dependent upon possession for the compensation to which the person is legally entitled for towing, storage, or labor associated with recovery or load salvage of any vehicle subject to registration that has been authorized to be removed by a public agency, a private property owner pursuant to Section 22658 of the Vehicle Code, or a lessee, operator, or registered owner of the vehicle. The lien is deemed to arise on the date of possession of the vehicle. Possession is deemed to arise when the vehicle is removed and is in transit, or when vehicle recovery operations or load salvage operations have begun. A person seeking to enforce a lien for the storage and safekeeping of a vehicle shall impose no charge exceeding that for one day of storage if, 24 hours or less after the vehicle is placed in storage, the vehicle is released. If the release is made more than 24 hours after the vehicle is placed in storage, charges may be imposed on a full-calendar-day basis for each day, or part thereof, that the vehicle is in storage. If a request to release the vehicle is made and the appropriate fees are tendered and documentation establishing that the person requesting release is entitled to possession of the vehicle, or is the owner’s insurance representative, is presented within the initial 24 hours of storage, and the storage facility fails to comply with the request to release the vehicle or is not open for business during normal business hours, then only one day’s charge may be required to be paid until after the first business day. A “business day” is any day in which the lienholder is open for business to the public for at least eight hours. If the request is made more than 24 hours after the vehicle is placed in storage, charges may be imposed on a full-calendar-day basis for each day, or part thereof, that the vehicle is in storage.

(2)“Documentation” that would entitle a person to possession of the vehicle includes, but is not limited to, a certificate of ownership, vehicle registration, information in the possession of the lienholder including ownership information obtained from the Department of Motor Vehicles or a facially valid registration found within the vehicle, or a notarized letter or statement from the legal or registered owner providing authorization to release to a particular person with a government-issued photographic identification card. Documentation that establishes that a person is the owner’s insurance representative includes, but is not limited to, a faxed letter or other letter from the owner’s insurance company. A lienholder is not responsible for determining the authenticity of documentation specifically described in this subdivision that establishes either a person’s entitlement to possession or that a person is the owner’s insurance representative.

(b)If the vehicle has been determined to have a value not exceeding four thousand dollars ($4,000), the lien shall be satisfied pursuant to Section 3072. Lien sale proceedings pursuant to Section 3072 shall commence within 15 days of the date the lien arises. No storage shall accrue beyond the 15-day period unless lien sale proceedings pursuant to Section 3072 have commenced. The storage lien may be for a period not exceeding 60 days if a completed notice of a pending lien sale form has been filed pursuant to Section 3072 within 15 days after the lien arises. Notwithstanding this 60-day limitation, the storage lien may be for a period not exceeding 120 days if any one of the following occurs:

(1)A Declaration of Opposition form is filed with the department pursuant to Section 3072.

(2)The vehicle has an out-of-state registration.

(3)The vehicle identification number was altered or removed.

(4)A person who has an interest in the vehicle becomes known to the lienholder after the lienholder has complied with subdivision (b) of Section 3072.

(c)If the vehicle has been determined to have a value exceeding four thousand dollars ($4,000) pursuant to Section 22670 of the Vehicle Code, the lien shall be satisfied pursuant to Section 3071. The storage lien may be for a period not exceeding 120 days if an application for an authorization to conduct a lien sale has been filed pursuant to Section 3071.

(d)(1)Any lien under this section shall be extinguished, and a lien sale shall not be conducted, if any one of the following occurs:

(A)The lienholder, after written demand to inspect the vehicle made by either personal service or certified mail with return receipt requested by the legal owner or the lessor, fails to permit the inspection by the legal owner or lessor, or his or her agent, within a period of time of at least 24 hours, but not to exceed 72 hours, after the receipt of that written demand, during the normal business hours of the lienholder. The legal owner or lessor shall comply with inspection and vehicle release policies of the impounding public agency.

(B)The amount claimed for storage exceeds the posted rates.

(2)“Agent” includes, but is not limited to, any person designated to inspect the vehicle by the request of the legal owner or lessor, in writing or by telephone, to the lienholder. A lienholder is not responsible for determining the authenticity of documentation establishing a person’s agency for the purposes of inspection of a vehicle.

(e)A lienholder shall not be liable for any claim or dispute directly arising out of the reliance on documentation specifically described in paragraph (2) of subdivision (a) for purposes of releasing a vehicle.

Notes of Decisions
Cited in 13 cases (2 in the last 5 years), 1991–2021 · leading case: Pintos v. Pac. Creditors Ass'n, 605 F.3d 665 (9th Cir. 2010).
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Pintos v. Pac. Creditors Ass'n, 605 F.3d 665 (9th Cir. 2010). · cites it 5× “See Cal. Civil Code §§ 3068.1 , 3068.2 (providing that a towing company has a lien dependent upon possession and a deficiency claim for unpaid towing charges).”
Pintos v. Pac. Creditors Ass'n, 565 F.3d 1106 (9th Cir. 2009). · cites it 5× “See Cal. Civil Code §§ 3068.1 , 3068.2 (providing that a towing company has a lien dependent upon possession and a deficiency claim for unpaid towing charges).”
Berry v. Hannigan, 92 Cal. Daily Op. Serv. 5335 (Cal. Ct. App. 1992). · cites it 2× “(Civ. Code, § 3068.1.) Berry argues that requiring him to release possession of vehicles upon payment by a credit card, thus ending the lien, deprives him of property without a hearing.”
Cnty. of Los Angeles v. Superior Court, 242 Cal. App. 4th 475 (Cal. Ct. App. 2015). “(Civ. Code, § 3068.1, subd. (a)(1).) Before the vehicle may be sold to satisfy this lien, the towing company (as lienholder) must provide notice to its registered and legal owner by certified mail.”
Pintos v. Pac. Creditors Ass'n, 504 F.3d 792 (9th Cir. 2007). “California Civil Code § 3068.1(a) provides for liens "dependent upon possession for the compensation to which [a] person is legally entitled for towing, storage, or labor associated with recovery or load salvage of any vehicle subject to registration that has been authorized to…”
Lincoln v. Repub. Ecology Corp., 765 F. Supp. 633 (C.D. Cal. 1991). “Code § 22851, Cal.Civ.Code § 3068.1. The last registered owner is presumed liable for the cost of removal and disposition of the vehicle.”
Cox v. Yellowstone Cnty., 795 F. Supp. 2d 1128 (D. Mont. 2011). “(Colorado’s Agistor’s Lien Act Foreclosure Provisions); Cal. Civ. Code § 3068.1 et seq. Accordingly, the Court finds that Yellowstone County has not shown that the lienholders’ or the governments’ interests would be adversely affected if a property owner such as Cox was allowed…”
Pintos v. Pac. Creditors (9th Cir. 2009). · cites it 4× “See Cal. Civil Code §§ 3068.1 , 3068.2 (providing that a towing company has a lien dependent upon possession and a deficiency claim for unpaid towing charges).”
Mares v. Lien Enf't CA4/1 (Cal. Ct. App. 2016). · cites it 2× “(Civ. Code, § 3068.1, subd. (a)(1); see County of Los Angeles v.”
Raimova v. West Coast Towing Servs. CA4/3 (Cal. Ct. App. 2021). “of any vehicle subject to registration that has been authorized to be removed by a public agency .”
Amazon Logistics, Inc. v. Mann Bros. Transp. Inc. (E.D. Cal. 2021). “14 Civ. Code § 3068.1(a)(1). Whereas, § 3068 governs liens on vehicles by a person who is legally 15 entitled to compensation for “making repairs or performing labor upon, and furnishing supplies or 16 materials for, and for the storage, repair, or safekeeping of, and for the…”
Jones v. City & Cnty. of San Francisco CA1/5 (Cal. Ct. App. 2015). “5, 22851; Civ. Code, § 3068.1.) B. Procedural History Jones filed his2 complaint for declaratory and injunctive relief in the San Francisco Superior Court on October 25, 2013.”
Show all 13 citing cases →
— Cal. Civil Code § 3068.1(a) — 4 cases
Pintos v. Pac. Creditors Ass'n, 605 F.3d 665 (9th Cir. 2010). “See Cal. Civil Code §§ 3068.1 , 3068.2 (providing that a towing company has a lien dependent upon possession and a deficiency claim for unpaid towing charges).”
Pintos v. Pac. Creditors Ass'n, 565 F.3d 1106 (9th Cir. 2009). “See Cal. Civil Code §§ 3068.1 , 3068.2 (providing that a towing company has a lien dependent upon possession and a deficiency claim for unpaid towing charges).”
Pintos v. Pac. Creditors Ass'n, 504 F.3d 792 (9th Cir. 2007). “California Civil Code § 3068.1(a) provides for liens "dependent upon possession for the compensation to which [a] person is legally entitled for towing, storage, or labor associated with recovery or load salvage of any vehicle subject to registration that has been authorized to…”
Pintos v. Pac. Creditors (9th Cir. 2009). “See Cal. Civil Code §§ 3068.1 , 3068.2 (providing that a towing company has a lien dependent upon possession and a deficiency claim for unpaid towing charges).”
— Cal. Civil Code § 3068.1(a)(1) — 1 case
Amazon Logistics, Inc. v. Mann Bros. Transp. Inc. (E.D. Cal. 2021). “14 Civ. Code § 3068.1(a)(1). Whereas, § 3068 governs liens on vehicles by a person who is legally 15 entitled to compensation for “making repairs or performing labor upon, and furnishing supplies or 16 materials for, and for the storage, repair, or safekeeping of, and for the…”
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