In most states, trainers do not have an express statutory lien for unpaid training fees and training-related expenses unrelated to the care of horses such as show entry fees and hauling. This means, unless a trainer has a written security agreement signed by the owner providing a lien on the horses in the event of nonpayment of training fees, the law is unclear as to whether a trainer can hold or sell the owner’s horse when training fees remain unpaid. You need to check your state’s statutes, however, as some states’ stableman’s liens do expressly provide a lien for training services. Oklahoma’s stableman’s lien statute, for example, expressly includes a lien for training services. You can find your state’s lien statutes on Equine Law and Horsemanship Safety.
What if My State Has a Stableman’s or Agister’s Lien Statute but No Trainer’s Lien? Currently, every state except Rhode Island has a stableman’s or agister’s lien statute. These statutes provide those who care for, board, pasture, or stable the horses of another with a lien on the horse if charges related to the care of the horse are not paid. Charges related to the "care" typically include the monhtly board rate, supplements, wormer, vaccinations, farrier, and veterinary services paid or advanced by the caregiver on behalf of the owner, and other services related to the care, health, and maintenance of the horses. See Carney v. Wallen, 665 N.W.2d 439 (Iowa Ct. App. 2003)(holding that a trainer who provided only training and did not also provide board or other services related to the "care" of the horses could not obtain a stableman’s lien because training services do not pertain to actions or services performed in the course of acting as a stable keeper).