This section is from the book "American Law Of Real Estate Agency", by William Slee Walker. Also available from Amazon: American law of real estate agency.
A real estate broker has no lien for services on a certificate of deposit belonging to the principal. Robinson v. Stewart, 97 Mich. 454, 56 N. W. 853; Arthur v. Sylvester, 105 Pa. St. 233; Jones' Appeal, 80 Pa. St. 54; Mayfield v. Turner, 180 I11. 332, 54 N. E. 418. See also Sec. 373.
However, there are cases upholding the broker's right to such special lien. Richards v. Gaskell, 39 Kan. 428, 18 P. 494; Carpenter v. Monsen, 92 Wis. 449, 65 N. W. 1027, 66 N. W. 692; Vinton v. Baldwin, 95 Ind. 433; Gerry v. Brumage, 46 Ind. 59.
 
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