## Facts

- Traci Bowden bought a Toyota under a retail installment contract assigned to Toyota Motor Credit Corporation (TMCC).
- TMCC perfected its purchase-money security interest; the original Virginia certificate of title listed TMCC’s lien, and TMCC retained the original title.
- Bowden fraudulently obtained a duplicate title by falsely claiming the lien was released and submitting a forged lien-release letter.
- The Virginia DMV issued a duplicate certificate of title showing no liens.
- Bowden sold the vehicle to C.L. Hyman Auto Wholesale, Inc. (Hyman), which paid value and relied on the clean duplicate title.
- After Bowden defaulted, TMCC discovered the fraud and demanded return of the vehicle; Hyman refused.

## Issues

1. Whether a lienholder with a properly perfected lien noted on an original certificate of title may enforce that lien against a later bona fide purchaser for value without notice when the lien is omitted from a DMV-issued duplicate title due to the owner’s fraud.

## Decision

- The Supreme Court of Virginia affirmed dismissal of TMCC’s detinue action.
- Hyman was treated as a bona fide purchaser for value without notice and was entitled to rely on the DMV-issued duplicate title showing no liens.
- TMCC’s lien was not enforceable against Hyman, and TMCC could not recover the vehicle from Hyman.

## Legal Principles

- Virginia’s motor vehicle titling statutes are designed to provide a central, reliable public record of ownership and liens through DMV-issued certificates of title.
- A bona fide purchaser for value without notice may rely on a certificate of title that shows no liens, even if a prior perfected lien was omitted from a duplicate title because of the owner’s fraud.
- When loss must be allocated between innocent parties under the titling system, the statutory scheme favors protecting bona fide purchasers who reasonably rely on DMV title records over prior lienholders whose liens are not reflected on the operative certificate presented in the transaction.

## Conclusion

Because Hyman purchased in good faith for value and relied on a DMV-issued duplicate title showing no liens, TMCC could not enforce its previously perfected lien against Hyman and could not obtain the vehicle in detinue.


Toyota Motor Credit Corp. v. C.L. Hyman Auto Wholesale, Inc., 256 Va. 243, 506 S.E.2d 14 (1998)