Ally Financial Inc. v. Pira, 96 N.E.3d 61

Ally Financial (plaintiff) held a perfected security interest in a 2013 Chevrolet Silverado previously owned by Robert Siudak.
Siudak left the vehicle with Michael Pira (defendant), a detailer/repairer, for work completed June 2014; repair charges were ~$658.
Siudak did not retrieve the vehicle; defendant charged daily storage (reduced to $60/day) and claimed storage fees (~$27,780 as of Oct. 2015) in addition to repair charges.
Plaintiff filed replevin to recover the vehicle; defendant asserted a common-law possessory (artisan) lien for repairs and storage and refused to release the vehicle unless paid.
Trial court granted plaintiff’s summary judgment on the sole legal question, holding the common-law lien covered repair charges but not post-completion storage; parties later resolved possession and the case was dismissed with prejudice; defendant appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a common-law possessory lien extends to post-repair storage fees	Lien limited to charges that add value (repairs); storage does not add value so lien excludes storage	Lien includes storage fees either by contract/consent or because defendant acted like a common carrier and incurred expense preserving the vehicle	Court held lien covers repair charges only; artisan lien does not extend to storage fees

National Bank of Joliet v. Bergeron Cadillac, Inc., 66 Ill.2d 140 (recognizes and preserves artisan/common-law possessory lien vs. perfected security interest)
Navistar Financial Corp. v. Allen’s Corner Garage & Towing Service, Inc., 153 Ill. App.3d 574 (artisan lien covers repair/towing value-added charges; storage lien only for common carriers or where carrier incurred expense beyond preserving lien)
Styck’s Body Shop, Inc. v. Country Mut. Ins. Co., 396 Ill. App.3d 241 (bailee/carrier lien principles; bailee may not retain property and also charge post-demand storage under lien theory)
Weiland Tool & Manufacturing Co. v. Whitney, 44 Ill.2d 105 (discusses limitations on retaining property and charging storage after demand)