Creston Aviation v. Textron Financial Corp.
Florida District Court of Appeal
900 So. 2d 727 (2005)
- Written by Angela Patrick, JD
Facts
Textron Financial Corporation (Textron) (defendant) repossessed a plane. Creston Aviation, Inc. (Creston) (plaintiff) had performed work on the airplane before Textron repossessed it but had not been paid for that work. To get paid, Creston had claimed a mechanic’s lien on the plane and recorded this lien with the Federal Aviation Administration (FAA). However, Creston had not recorded the lien with the State of Florida or Broward County, where the work had occurred. Creston and Textron each sued the other in Florida state court over the validity of Creston’s lien. The district court granted summary judgment to Textron, finding that Creston’s lien was unenforceable because the lien had not been recorded with Broward County as required by Florida state law. Creston appealed, arguing that the FAA’s lien-recording requirements preempted any state law that attempted to impose additional recording requirements and, therefore, that Creston’s FAA recording was enough to make its lien enforceable.
Rule of Law
Issue
Holding and Reasoning (Stevenson, J.)
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