Under Bus. & Prof. Code 21711, a good faith purchaser at a lien sale held under the California Self-Service Storage Facility Act (Bus. & Prof. Code, § 21700 et seq.) takes the purchased contents of a storage unit free and clear of unit’s lessee’s claims that the lessor violated the Storage Facility Act.  This is true even if the lessor violates the Storage Facility Act by failing to enter into a written lease with the lessee.  Furthermore, ownership of the unit’s contents is transferred at the sale even though the lessor never acquired title to the contents itself.  The Storage Facility Act gives the lessor a possessory lien in the contents, and it is the foreclosure of that lien that transfers title to the purchaser at the sale.

California Court of Appeal, Second District, Division 6 (Yegan, J.); May 31, 2018; 2018 Cal. App. LEXIS 508