Tennessee Code Annotated

Tenn. Code Ann. § 66-19-103 (2026)

Garagekeeper's or towing firm's lien

✓ current as of May 2026

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(a) As used in this section:
- (1) "Garagekeeper" has the same meaning as defined in § 55-31-101; and
- (2) "Rental vehicle company" means a person or entity, or a subsidiary or affiliate of a person or entity, including a franchisee, in the business of renting motor vehicles to the public.

(b)
- (1)
  - (A) Garagekeepers are entitled to a lien upon all motor vehicles that lawfully come into their possession and are retained in their possession until all reasonable charges due are paid. A garagekeeper may, after thirty (30) days, enforce such lien in the manner prescribed for the enforcement of artisans' liens under §§ 66-14-102 - 66-14-106; except, that the garagekeeper:
    - (i) Is only required to advertise the sale on the department of revenue website developed pursuant to § 55-31-302(c); and
    - (ii) Shall include the vehicle identification number (VIN), if it is ascertainable, in the notice required pursuant to § 66-14-103 and in the advertisement of the sale described in § 66-14-104.
  - (B) If the motor vehicle, including any associated rental equipment, clearly identifies a rental vehicle company, the United States department of transportation (USDOT) number issued by the federal motor carrier safety administration (FMCSA), a registration plate issued and attached to the motor vehicle described in § 55-4-113(a)(2), or a registration plate issued and attached to a trailer described in § 55-4-113(a)(5), and a garagekeeper lawfully comes into possession of the vehicle and any associated equipment, then the garagekeeper shall notify the rental vehicle company, the owner of the motor vehicle identified by the USDOT number, or the owner assigned to the registration plate issued and attached to the motor vehicle described in § 55-4-113(a)(2) or a registration plate issued and attached to the trailer described in § 55-4-113(a)(5), at the address identified with the USDOT number, rental equipment information, or the vehicle's registration within three (3) business days of taking possession of such vehicle or equipment using a nationally recognized overnight delivery carrier, other than the United States postal service, requesting proof of delivery.
- (2) The commissioner of commerce and insurance or the commissioner's designee shall notify the commissioner of safety of violations of subdivision (b)(1). Upon receiving such notice, the commissioner of safety shall suspend any contract that the state may have for towing services with the garagekeeper for a period of sixty (60) days or notify the appropriate authority to suspend all such contracts with the state.
- (3)
  - (A) In addition to any other penalty provided for a violation of this section, a violation of subdivision (b)(1) is also a violation of the Tennessee Consumer Protection Act of 1977, compiled in title 47, chapter 18, part 1. A violation of subdivision (b)(1) constitutes an unfair or deceptive act or practice affecting trade or commerce, and is subject to the penalties and remedies as provided in the Tennessee Consumer Protection Act of 1977, in addition to the penalties and remedies provided in this section.
  - (B) The attorney general and reporter has all of the investigative and enforcement authority that the attorney general and reporter has under the Tennessee Consumer Protection Act of 1977 relating to alleged violations of subdivision (b)(1). The attorney general and reporter may institute any proceedings involving alleged violations of this part in Davidson County circuit or chancery court or any other venue otherwise permitted by law.
  - (C) Costs of any kind or nature must not be taxed against the attorney general and reporter or the state in actions commenced under this section.
  - (D) A rental vehicle company, the owner of the motor vehicle identified by the USDOT number, or the owner assigned to the registration plate issued and attached to the motor vehicle described in § 55-4-113(a)(2) or a registration plate issued and attached to the trailer described in § 55-4-113(a)(5) may seek relief under the Tennessee Consumer Protection Act, in addition to remedies provided under this section.
- (4) A garagekeeper shall not collect any storage or related fees for any period of time in which the garagekeeper was in violation of subdivision (b)(1) with respect to a motor vehicle or associated equipment.
- (5) The commissioner of commerce and insurance is authorized to promulgate rules to effectuate this section. The rules must be promulgated in accordance with the Uniform Administrative Procedures Act, compiled in title 4, chapter 5.
- (6) Subdivisions (b)(1)(B) and (b)(2)-(5) and § 55-32-308 do not apply to new or used motor vehicle dealers licensed under title 55, chapter 17, part 1.

(c) A person, firm, or entity does not have a right to a lien on a vehicle that has been towed in violation of title 55, chapter 32. If the owner of the vehicle is not present, then within fifteen (15) minutes of a person, firm, or entity towing the vehicle pursuant to this chapter, the person, firm, or entity shall notify local law enforcement of the VIN, registration information, license plate number, and description of the vehicle. A violation of this subsection (c) by a person, firm, or entity is a Class A misdemeanor. Local law enforcement shall keep a record of such information, which must be available for public inspection.

(d)
- (1) Any authorization made by a police department to tow a vehicle must be made in writing. Such authorization must include:
  - (A) The name of the officer giving authorization;
  - (B) The year, make, model, and color of the vehicle to be towed;
  - (C) The reason for the tow;
  - (D) The license plate number, if any; and
  - (E) The VIN, if it is ascertainable.
- (2) The officer giving authorization shall post a copy of the authorization with the vehicle and the copy of the authorization must remain with the vehicle until the vehicle is claimed by the owner.

(e) A person, firm, or entity, unless licensed and regulated under title 55, chapter 17, part 1, does not have a right to a lien against a lienor, who is also the seller of such motor vehicle or who retains title under a title retention or conditional sale agreement, for repairs in excess of two hundred fifty dollars ($250) made on such motor vehicle, unless the person, firm, or entity making the repairs has received a written authorization from the lienor or seller to make such repairs on the motor vehicle.

Amended by 2024 Tenn. Acts, ch. 1017,s 5, eff. 7/1/2024.

Amended by 2023 Tenn. Acts, ch. 229, s 3, eff. 7/1/2023.

Amended by 2023 Tenn. Acts, ch. 229, s 2, eff. 4/25/2023.

Amended by 2023 Tenn. Acts, ch. 229, s 1, eff. 4/25/2023.

Amended by 2022 Tenn. Acts, ch. 826, Secs.s 1, s 2 eff. 4/14/2022.

Amended by 2014 Tenn. Acts, ch. 886, s 2, eff. 7/1/2014.

Code 1932, § 7979; modified; T.C.A. (orig. ed.), § 64-1903; Acts 1983, ch. 463, § 3; 1984, ch. 866, § 1; 1996, ch. 868, §§ 1, 6, 8; 1997 , ch. 73, §§ 1, 5; 1998, ch. 733, § 1; 1998, ch. 760, § 2; 1998, ch. 1027, §§ 1 - 3, 5; 1999, ch. 1, § 3; 1999, ch. 235, § 1; 2004, ch. 460, § 1; 2005, ch. 275, § 1; 2011 , ch. 244, § 2.

Notes of Decisions

Cited in 9 cases, 1999–2020 · leading case: Ware v. Tow Pro Custom Towing & Hauling, Inc., 289 F. App'x 852 (6th Cir. 2008).

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Ware v. Tow Pro Custom Towing & Hauling, Inc., 289 F. App'x 852 (6th Cir. 2008). “”); and (3) Section 66-19-103 of the Tennessee Code prohibited Tow Pro from collecting any storage or related fees unless certain circumstances were met, see Tenn. Code Ann. § 66-19-103 (setting forth the requirements for a “[g]aragekeeper’s or towing firm’s lien”).”

In Re Hamby, 360 B.R. 657 (Bankr. E.D. Tenn. 2007). · cites it 3× “(b) For purposes of this section, “ga-ragekeeper” means any operator of a parking place or establishment, motor vehicle storage facility, or establishment for the servicing, repair or maintenance of vehicles.”

Dorian Jones v. Ronald Hicks, Individually & DBA R & R Collision (Tenn. Ct. App. 2010). · cites it 6× “Hicks alleged in his counterclaim that he had a right to sell the Jeep as an “abandoned vehicle under the provisions of Tenn. Code Ann. § 66-19-103 et seq.,” but the trial court appears to have based its order in favor of Hicks on equitable principles.”

In Re Crisp, 430 B.R. 831 (Bankr. W.D. Tenn. 2010). · cites it 6× “In this case, McDaniels became entitled to a garagekeeper’s lien on Crisp’s vehicle pursuant to T.C.A. § 66-19-103 which provides that: Garagekeepers or establishments substantially in the business of towing vehicles for hire, pursuant to the provisions of title 55, chapter 16,…”

Wondimu Borena v. Jason Jacocks (Tenn. Ct. App. 2017). · cites it 3× “Under a purported mechanic’s lien, Tennessee Code Annotated Section 66-19-103, Appellee sold Appellant’s vehicle for $4,500.”

State of Tennessee v. Elizabeth Lynn Schmitz (Tenn. Crim. App. 2020). · cites it 3× “T.C.A. § 66-19-103(a)-(b). Here, the record shows that Defendant requested her insurance company to tow her car.”

Memphis Area Teachers Credit Union v. David Jones (Tenn. Ct. App. 2010). · cites it 4× “T.C.A. § 66-19-103 (2009 Supp.). 2 The case was originally set for May 15, 2008.”

Neal Roberson v. West Nashville Diesel, Inc. (Tenn. Ct. App. 2006). · cites it 4× “7 Absent allegations of 5 Although the trial court also cited Tenn. Code Ann. § 66-19-103 , that section deals with garage keeper’s liens, an issue separate from the lien for repairs, as discussed below.”

Simpson v. Bicentennial Volunteers (Tenn. Ct. App. 1999). · cites it 3× “In contrast, Tenn. Code Ann. § 66-19-103 provides a lien for garagekeepers: (a) Garagekeepers or establishments substantially in the business of towing vehicles for hire, pursuant to the provisions of title 55, chapter 16, hereinafter referred to as “towing firms” shall be…”

— Tenn. Code Ann. § 66-19-103(a) — 1 case

State of Tennessee v. Elizabeth Lynn Schmitz (Tenn. Crim. App. 2020). “T.C.A. § 66-19-103(a)-(b). Here, the record shows that Defendant requested her insurance company to tow her car.”

— Tenn. Code Ann. § 66-19-103(a)(1)(A) — 1 case

State of Tennessee v. Elizabeth Lynn Schmitz (Tenn. Crim. App. 2020). “T.C.A. § 66-19-103(a)-(b). Here, the record shows that Defendant requested her insurance company to tow her car.”

— Tenn. Code Ann. § 66-19-103(a)(l)(A) — 1 case

In Re Crisp, 430 B.R. 831 (Bankr. W.D. Tenn. 2010). “In this case, McDaniels became entitled to a garagekeeper’s lien on Crisp’s vehicle pursuant to T.C.A. § 66-19-103 which provides that: Garagekeepers or establishments substantially in the business of towing vehicles for hire, pursuant to the provisions of title 55, chapter 16,…”

— Tenn. Code Ann. § 66-19-103(b) — 1 case

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