Fulton v. Allard's Moving & Storage, Inc., 139 N.H. 582 (1995)

The plaintiff argues that a carrier’s lien does not provide a lien on the plaintiff’s property for storage charges because after moving the goods into storage the carrier becomes a warehouseman and consequently a lien for storage would be available only under the warehouseman’s lien statute, RSA 382-A:7-209 (1994). We disagree. RSA 382-A:7-307 expressly states that a carrier’s lien can cover charges for both transportation and storage. While storage of the plaintiff’s property in this case is somewhat more than incidental to the move, it is substantially connected with the move. The storage fees accrued only because the plaintiff failed to remove her property. Therefore, the defendant has a valid carrier’s lien enforceable against the plaintiff for the storage fees. See McCausland v. Tide-Mayflower Mov. & Storage, 499 So. 2d 1378, 1381 (Ala. 1986).