Miller v. Economics Laboratory, Inc.

This cause is before us on appeal from an order granting a summary judgment and dismissing with prejudice appellant’s counterclaim against appellee. Appellant contends that the dismissal was erroneous because a genuine issue of material fact existed as to whether Miller was entitled to a statutory or equitable lien against a shipment of appellee’s goods for unpaid freight charges incurred in three prior shipments.

The Uniform Commercial Code, Section 7-307(1), unambiguously limits a private carrier’s statutory lien to charges incurred subsequent to the date of the carrier’s receipt of the…