Colorado Revised Statutes

Colo. Rev. Stat. § 38-20-105 (2026)

Lien of common carrier

✓ current as of July 2026

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(1) Except as provided in subsection (2) of this section, every common carrier of goods or passengers who, at the request of the owner of any personal goods, carries, conveys, or transports the same from one place to another and every other person who safely keeps or stores any personal property at the request of the owner or person lawfully in possession of the personal property has a lien upon the personal property for reasonable charges for the transportation, storage, or keeping of the personal property and for all reasonable and proper advances made by the common carrier or warehouse, in accordance with the usage and custom of common carriers and warehouses.

(2) In accordance with section 40-10.1-405 (5)(a), this section does not grant a towing carrier a lien on the contents of a vehicle if the vehicle was towed nonconsensually, as defined in section 40-10.1-101 (13).

Source: L. 1883: p. 237, § 2. G.S. § 2119. R.S. 08: § 4014. C.L. § 6431. CSA: C. 101, § 4. CRS 53: § 86-1-4. C.R.S. 1963: § 86-1-4. L. 76: Entire section amended, p. 314, § 68, effective May 20. L. 2022: Entire section amended, (HB 22-1314), ch. 416, p. 2948, § 13, effective August 10.

Cross references: For liens of warehousemen and enforcement thereof, see §§ 4-7-209 and 4-7-210; for lien of a carrier on goods covered by a bill of lading and enforcement thereof, see §§ 4-7-307 and 4-7-308.

Notes of Decisions

Cited in 2 cases, 1994–2015 · leading case: Bedee v. Am. Med. Response of Colorado, 2015 COA 128 (Colo. Ct. App. 2015).

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Bedee v. Am. Med. Response of Colorado, 2015 COA 128 (Colo. Ct. App. 2015). · cites it 3× “For example, section 38-20-105, C.R.S.2014, permits common carriers of goods and passengers to impose a lien upon their clients, but does not define the term "common carrier," nor is that term defined in the definitions section for part 1 of that article, section 38-20-101, C.”

Jam Action, Inc. v. Colorado State Patrol, 890 P.2d 210 (Colo. Ct. App. 1994). · cites it 3× “Likewise, we conclude that there is no conflict between the CSP Policy and § 38-20-105, C.R.S. (1982 Repl. Vol. 16A).”

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