District Of Columbia § 28:7-210 - Enforcement of warehouse’s lien.
Full text of District Of Columbia D.C. Code § 28:7-210 — Enforcement of warehouse’s lien., with citation guidance and answers to common questions.
§ 28:7-210. Enforcement of warehouse’s lien.
28:7-210Except as otherwise provided in subsection (b) of this section, a warehouse’s lien may be enforced by public or private sale of the goods, in bulk or in packages, at any time or place and on any terms that are commercially reasonable, after notifying all persons known to claim an interest in the goods. The notification must include a statement of the amount due, the nature of the proposed sale, and the time and place of any public sale. The fact that a better price could have been obtained by a sale at a different time or in a method different from that selected by the warehouse is not of itself sufficient to establish that the sale was not made in a commercially reasonable manner.
The warehouse sells in a commercially reasonable manner if the warehouse sells the goods in the usual manner in any recognized market therefor, sells at the price current in that market at the time of the sale, or otherwise sells in conformity with commercially reasonable practices among dealers in the type of goods sold.
A sale of more goods than apparently necessary to be offered to ensure satisfaction of the obligation is not commercially reasonable, except in cases covered by paragraph (2) of this subsection.
A warehouse may enforce its lien on goods, other than goods stored by a merchant in the course of its business, only if the following requirements are satisfied:
All persons known to claim an interest in the goods must be notified.
The notification must include an itemized statement of the claim, a description of the goods subject to the lien, a demand for payment within a specified time not less than 10 days after receipt of the notification, and a conspicuous statement that unless the claim is paid within that time the goods will be advertised for sale and sold by auction at a specified time and place.
The sale must conform to the terms of the notification.
The sale must be held at the nearest suitable place to where the goods are held or stored.
After the expiration of the time given in the notification, an advertisement of the sale must be published once a week for 2 weeks consecutively in a newspaper of general circulation where the sale is to be held. The advertisement must include a description of the goods, the name of the person on whose account the goods are being held, and the time and place of the sale. The sale must take place at least 15 days after the first publication. If there is no newspaper of general circulation where the sale is to be held, the advertisement must be posted at least 10 days before the sale in not fewer than 6 conspicuous places in the neighborhood of the proposed sale.
Before any sale pursuant to this section, any person claiming a right in the goods may pay the amount necessary to satisfy the lien and the reasonable expenses incurred in complying with this section. In that event, the goods may not be sold and must be retained by the warehouse subject to the terms of the receipt and this article.
A warehouse may buy at any public sale held pursuant to this section.
A purchaser in good faith of goods sold to enforce a warehouse’s lien takes the goods free of any rights of persons against which the lien was valid, despite the warehouse’s noncompliance with this section.
A warehouse may satisfy its lien from the proceeds of any sale pursuant to this section but shall hold the balance, if any, for delivery on demand to any person to which the warehouse would have been bound to deliver the goods.
The rights provided by this section are in addition to all other rights allowed by law to a creditor against a debtor.
If a lien is on goods stored by a merchant in the course of its business, the lien may be enforced in accordance with subsection (a) or (b) of this section.
A warehouse is liable for damages caused by failure to comply with the requirements for sale under this section and, in case of willful violation, is liable for conversion.
Annotations
“Warehouse”. Section 7-102.
“Term”. Section 1-201.
“Rights”. Section 1-201.
“Purchaser”. Section 1-201.
“Person”. Section 1-201.
“Notifies”. Section 1-202.
“Notification”. Section 1-202.
“Goods”. Section 7-102.
“Good faith”. Section 1-201 [7-102].
“Document of Title”. Section 1-201.
“Delivery”. Section 1-201.
“Creditor”. Section 1-201.
“Conspicuous”. Section 1-201.
“Bill of lading”. Section 1-201.
Sections 2-706, 7-403, 7-603 and Part 6 of Article 9.
4. If a warehouse has both a warehouse lien and a security interest, the warehouse may enforce both the lien and the security interest simultaneously by using the procedures of Article 9. Section 7-210 adopts as its touchstone “commercial reasonableness” for the enforcement of a warehouse lien. Following the procedures of Article 9 satisfies “commercial reasonableness.”
3. A warehouses may have recourse to an interpleader action in appropriate circumstances. See Section 7-603.
2. The provisions of subsections (d) and (e) permitting the bailee to bid at public sales and confirming the title of purchasers at foreclosure sales are designed to secure more bidding and better prices and remain unchanged from former Section 7-210.
1. Subsection (a) makes “commercial reasonableness” the standard for foreclosure proceedings in all cases except non-commercial storage with a warehouse. The latter category embraces principally storage of household goods by private owners; and for such cases the detailed provisions as to notification, publication and public sale are retained in subsection (b) with one change. The requirement in former Section 7-210(2)(b) that the notification must be sent in person or by registered or certified mail has been deleted. Notification may be sent by any reasonable means as provided in Section 1-202. The swifter, more flexible procedure of subsection (a) is appropriate to commercial storage. Compare seller’s power of resale on breach by buyer under the provisions of the Article on Sales ( Section 2-706). Commercial reasonableness is a flexible concept that allows for a wide variety of actions to satisfy the rule of this section, including electronic means of posting and sale.
Update to accommodate electronic commerce and for style.
Former Section 7-210.
“Warehouseman”. Section 7-102.
“Term”. Section 1-201.
“Rights”. Section 1-201.
“Purchaser”. Section 1-201.
“Person”. Section 1-201.
“Notifies”. Section 1-201.
“Notification”. Section 1-201.
“Goods”. Section 7-102.
“Good faith”. Section 1-201.
“Document”. Section 7-102.
“Delivery”. Section 1-201.
“Creditor”. Section 1-201.
“Conspicuous”. Section 1-201.
“Bill of lading”. Section 1-201.
Section 7-403.
2. The provisions of subsections (4) and (5) permitting the bailee to bid at public sales and confirming the title of purchasers at foreclosure sales are designed to secure more bidding and better prices.
1. Subsection (1) makes “commercial reasonableness” the standard for foreclosure proceedings in all cases except noncommercial storage with a warehouseman. The latter category embraces principally storage of household goods by private owners; and for such cases the detailed provisions as to notification, publication and public sale, found in Section 33 of the Uniform Warehouse Receipts Act, are retained in subsection (2). The swifter, more flexible procedure of subsection (1) is appropriate to commercial storage. Compare seller’s power of resale on breach by buyer under the provisions of the Article on Sales ( Section 2-706).
Rewritten; simplified foreclosure proceeding provided for all liens other than warehousemen’s lien in non-commercial storage.
Section 33, Uniform Warehouse Receipts Act.
Source: official District Of Columbia text · Last verified 2026-08-27
Frequently Asked Questions About District Of Columbia § 28:7-210
What does D.C. Code § 28:7-210 cover?
Section 28:7-210 ("Enforcement of warehouse’s lien.") is part of the D.C. Code, the codified statutory law of District Of Columbia. It sets out the legal rule or procedure described in the text above. Statutes are amended regularly, so always verify against the official source.
How do I cite District Of Columbia § 28:7-210?
A common citation format is "D.C. Code § 28:7-210" (District Of Columbia). Legal writing may require the code abbreviation, section number, and year or edition. Match the style required by your court, professor, or publisher.
Is this the official text of District Of Columbia law?
No. This page is for research and education and may not include the most recent amendments. For official current law, check the District Of Columbia official source linked on this page or consult a licensed District Of Columbia attorney.
How does District Of Columbia § 28:7-210 apply to my situation?
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Sources & Verification
Not legal advice. Verify against the official source and consult a licensed attorney in District Of Columbia.