This section is from the book "Popular Law Library Vol5 Sales, Personal Property, Bailments, Carriers, Patents, Copyrights", by Albert H. Putney. Also available from Amazon: Popular Law-Dictionary.
"The right to a specific lien on property in the hands of a tradesman or artisan for the price of work done upon it is of common-law origin,8 but the right has been long extended to every bailee who has by his labor or skill conferred some value on the thing bailed,9 in the absence of anything in the contract inconsistent therewith.10 No express agreement for a lien is necessary,11 and it does not seem material whether the agreement be to pay a stipulated price or only an implied contract to pay a reasonable price.12 The bailee must, however, have an exclusive legal possession,13 of the subject-matter created by some express or implied contract existing between the bailor and the bailee.,, 14
Wilson vs. Guyton, 8 Gill (Md.) ,213; East vs. Ferguson, 59 Ind. 169.
9 Garrard vs. Moody, 48 Ga., 96.
10 Hanna vs. Phelps, 7 Ind., 21; 63
Am. Dec, 410.
11 Busfield vs. Wheeler, 14 Allen
(Mass.), 139.
12 Morgan vs. Congdon. 4 N. Y., 552. 13 Heard vs. Brewer, 4 Daly (N. Y.),
136. 14 Small vs. Robinson, 69 Me., 425;
31 Am. Rep., 299.
 
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