ILCS » Chapter 770 · Act 45
Illinois Compiled Statutes

770 ILCS 45/1 (2026)

Every person, firm or corporation who has expended labor, skill or materials upon any chattel, or has furnished storage for said chattel, at the request of its owner, reputed owner, or authorized agent of the owner, or lawful possessor thereof, shall have a lien upon such chattel beginning on the date of the commencement of such expenditure of labor, skill and materials or of such storage for the contract price for all such expenditure of labor, skill or materials, or for all such storage, or in the absence of such contract price, for the reasonable worth of such expenditure of labor, skill and materials, or of such storage, for a period of one year from and after the completion of such expenditure of labor, skill or materials, or of such storage, notwithstanding the fact that the possession of such chattel has been surrendered to the owner, or lawful possessor thereof

✓ current as of May 2026
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(770 ILCS 45/1) (from Ch. 82, par. 40)
    Sec. 1. Every person, firm or corporation who has expended labor, skill or materials upon any chattel, or has furnished storage for said chattel, at the request of its owner, reputed owner, or authorized agent of the owner, or lawful possessor thereof, shall have a lien upon such chattel beginning on the date of the commencement of such expenditure of labor, skill and materials or of such storage for the contract price for all such expenditure of labor, skill or materials, or for all such storage, or in the absence of such contract price, for the reasonable worth of such expenditure of labor, skill and materials, or of such storage, for a period of one year from and after the completion of such expenditure of labor, skill or materials, or of such storage, notwithstanding the fact that the possession of such chattel has been surrendered to the owner, or lawful possessor thereof.
(Source: Laws 1921, p. 508.)

    
Notes of Decisions
Cited in 4 cases, 1999–2017 · leading case: Country Mut. Ins. v. Styck's Body Shop, Inc., 918 N.E.2d 1195 (Ill. App. Ct. 2009).
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Country Mut. Ins. v. Styck's Body Shop, Inc., 918 N.E.2d 1195 (Ill. App. Ct. 2009). · cites it 2× “In July 2003, Body Shop replied, denying Country's right to possession of the vehicles and asserting affirmative defenses based on (1) possessory lien rights under the Labor and Storage Lien Act (770 ILCS 45/1 through 8 (West 2000)) and the Labor and Storage Lien (Small Amount)…”
Est. of Downs v. Webster, 716 N.E.2d 1256 (Ill. App. Ct. 1999). · cites it 2× “In the Act, the Labor and Storage Lien Act (770 ILCS 45/1 (West 1996)), and the Labor and Storage Lien (Small Amount) Act (770 ILCS 50/1 (West 1996)), the Illinois legislature, like the common law, has followed two distinct approaches to liens on stored property and the rights…”
Ally Fin. Inc. v. Pira, 2017 IL App (2d) 170213 (Ill. App. Ct. 2017). “The defendant asserted affirmative defenses based on: (1) the Labor and Storage Lien Act ( 770 ILCS 45/1 et seq . (West 2000)); (2) the Labor and Storage Lien (Small Amount) Act ( 770 ILCS 50/1 et seq .”
Country Mut. Ins. Co. v. Styck's Body Shop, Inc. (Ill. App. Ct. 2009). “In July 2003, Body Shop replied, denying Country's right to possession of the vehicles and asserting affirmative defenses based on (1) possessory lien rights under the Labor and Storage Lien Act (770 ILCS 45/1 through 8 (West 2000)) and the Labor and Storage Lien (Small Amount)…”
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