Va. Code » Title 43. Mechanics' and Certain Other Liens » Chapter 4. Liens of Innkeepers, Livery Stable, Garage and Marina Keepers, Mechanics and Bailees
Virginia Code

Va. Code Ann. § 43-31 (2026)

Lien of innkeepers, etc

✓ current as of May 2026
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Every innkeeper and the keeper of a boardinghouse or house of private entertainment shall have a lien upon, and may retain possession of, the baggage and other property of his guest or boarder brought upon his premises, and also upon the property of the employer of such guest or boarder, controlled and brought upon the premises by such guest or boarder in the course of his employment, for the proper charges due from such guest for his board and lodging.

Code 1919, § 6444.

Notes of Decisions
Cited in 5 cases, 1972–2001 · leading case: McCary v. Commonwealth, 548 S.E.2d 239 (Va. Ct. App. 2001).
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McCary v. Commonwealth, 548 S.E.2d 239 (Va. Ct. App. 2001). · cites it 2× “finds its justification in the fact that it is commonly known that those who operate [hotels and motels] are understandably interested in maximum paying occupancy and thus could be expected promptly to clear the room of a guest who has overstayed so that another guest may be…”
O'MALLEY v. Rapidan River Farm, 24 B.R. 900 (E.D. Va. 1982). · cites it 3× “Instead, the Epperley Court went on to consider the independent source and nature of protection afforded various Virginia businesses by virtue of the possessory lien provisions found throughout Va.Code §§ 43-31 to 43-33. The legislative purpose underlying these…”
Epperley v. Woodyard (In Re Epperley), 4 B.R. 124 (Bankr. W.D. Va. 1980). “The Virginia legislature has enacted for the benefit of certain businesses and enterprises a series of possessory lien provisions § 43-31 provides this protection for innkeepers and boarding house keepers upon the property of their guests.”
Newport News Shipbuilding Employees' Credit Union, Inc. v. B & L Auto Body, Inc., 400 S.E.2d 512 (Va. 1991). · cites it 3× “The statute establishes the procedure for enforcement of liens acquired under Code § 43-31 (lien of innkeepers and others), § 43-32 (lien of keepers of livery stables, garages, and vehicles, among others), and § 43-33 (lien of mechanic for repairs to articles of personal…”
W. T. Grant Co. v. Martin, 7 Va. Cir. 422 (1972). · cites it 5× “Code of Virginia, § 43-31. Plaintiff brings this action in detinue for the return of the property, contending that their prior lien has priority over the innkeeper's lien.”
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