ILCS » Chapter 770 · Act 50
Illinois Compiled Statutes

770 ILCS 50/1 (2026)

Every person expending labor, services, skill or material upon or furnishing storage for any chattel at the request of or with the consent of its owner, authorized agent of the owner, or lawful possessor thereof, in the amount of $2,000 or less, shall have a lien upon such chattel beginning upon the date of commencement of such expenditure of labor, services, skill, or materials or furnishing of storage, for the contract price for all such expenditure of labor, services, skill, or material, until the possession of such chattel is voluntarily relinquished to such owner or authorized agent, or to one entitled to the possession thereof

✓ current as of May 2026
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(770 ILCS 50/1) (from Ch. 82, par. 47a)
    Sec. 1. Every person expending labor, services, skill or material upon or furnishing storage for any chattel at the request of or with the consent of its owner, authorized agent of the owner, or lawful possessor thereof, in the amount of $2,000 or less, shall have a lien upon such chattel beginning upon the date of commencement of such expenditure of labor, services, skill, or materials or furnishing of storage, for the contract price for all such expenditure of labor, services, skill, or material, until the possession of such chattel is voluntarily relinquished to such owner or authorized agent, or to one entitled to the possession thereof.
    For the purposes of this Act, a person, other than a driver or a person otherwise in control of a fire, police, emergency or public utility vehicle on official business, consents to removal by towing of his or her vehicle when he or she without authorization parks such vehicle upon private property while having notice that unauthorized vehicles will be towed from such property by the owner of such property, or agent thereof, at the vehicle owner's expense, where such notice is provided pursuant to State law, local ordinances or regulation by any state or local agency. Such notice must include a sign of at least 24 inches in height by 36 inches in width posted in a conspicuous place in the affected area at least 4 feet from the ground but not more than 8 feet from the ground. Such sign shall be either illuminated or painted with reflective paint, or both and shall state the amount of towing charges to which the person may be subjected. However, the requirement of the sign provided for in this section shall not apply to residential property which, paying due regard to the circumstances and the surrounding area, is clearly reserved or intended exclusively for the use or occupation of residents or their vehicles.
    The lien established herein shall also apply to labor, services, skills or material upon or furnishing storage for towed vehicles performed by any relocator or any other towing service pursuant to the order of a law enforcement official or agency in accordance with Sections 4-201 through 4-214 of The Illinois Vehicle Code. The lien created herein shall be valid even though the towing and storage is performed without the vehicle owner's consent.
(Source: P.A. 85-1283.)

    
Notes of Decisions
Cited in 6 cases (2 in the last 5 years), 1999–2026 · 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). “(West 2000)); (2) the Labor and Storage Lien (Small Amount) Act ( 770 ILCS 50/1 et seq . (West 2000)); (3) section 4-203 of the Illinois Vehicle Code ( 625 ILCS 5/4-203 (West 2000) ); and (4) "common law artisan's liens.”
King Auto Sales, Inc. v. Act Now Towing, 2021 IL App (5th) 200143 (Ill. App. Ct. 2021). “-2- (2) the Small Lien Act, rather than the Lien Act, is applicable because the amount at issue is less than $2000 (see 770 ILCS 50/1 (West 2018)). ¶6 On September 10, 2019, King filed an amended complaint.”
BMO Harris Bank N.A. v. Dist. Recovery Inc., 2026 IL App (1st) 241028-U (Ill. App. Ct. 2026). · cites it 7× “1-24-1028 $2,000 limit on the lien it is entitled to under the Small Amount Act (770 ILCS 50/1 (West 2018)). BMO counters that neither ICC regulation 17120.”
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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