BMI Fed. Credit Union v. Charlton, 100 N.E.3d 986

BMI Federal Credit Union held a purchase-money security interest in a 2004 Chrysler Pacifica; a lien notation was recorded on the vehicle title showing a lien date of January 25, 2013.
Maurice Charlton (titled owner) defaulted on the loan; BMI sought possession of the vehicle from Evans Automotive Repair, which had custody of the car.
Evans stored and performed repairs on the Pacifica beginning in early 2014 and claimed a common-law possessory (artisan) lien for unpaid repair and storage charges.
The magistrate and trial court found BMI’s title-noted lien was perfected before Evans became a possessory lienholder and granted BMI summary judgment; Evans’ cross-motion was denied.
Evans appealed the priority ruling, arguing a possessory artisan lien should take precedence; the appeals court reviewed whether R.C. 4505.13(B) (title notation) controls over possessory lien priority rules.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a prior security interest noted on a vehicle title defeats a later common-law possessory (artisan) lien	BMI: Title notation under R.C. 4505.13(B) makes its perfected security interest valid against subsequent lienholders	Evans: Common-law possessory lien should have priority over later-recorded purchase-money/security liens; shops rely on that priority for payment	The title-noted security interest prevails; BMI’s perfected lien (noted on the certificate) has priority over Evans’ later possessory lien

Commonwealth v. Berry, 2 Ohio St.2d 169 (Ohio 1965) (holds that the motor-vehicle title-notification statute controls priority over artisan/possessory liens)
Andrianos v. Community Traction Co., 155 Ohio St. 47 (Ohio 1948) (explains that a specific statutory provision controls over a general statute on the same subject)