Appeals Court Upholds Storage Firm Liability

North Carolina's appeals court affirmed most of a judgment against storage facility operators who withheld a customer's property.

Updated on Nov. 2, 2026 in Property Crime

Isometric editorial illustration of a row of slate blue roll-up storage doors on a cream concrete apron, one oxblood padlock hanging from a hasp. — The North Carolina Court of Appeals affirmed most of a judgment against Moore County storage operators who over-locked a customer's units and kept the inventory for years despite repeated demands for its return. AI Illustration. Upload story photo >

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The North Carolina Court of Appeals affirmed in part and vacated and remanded in part a liability and damages judgment against the operators of a storage facility that over-locked a customer's units and kept its inventory for several years despite repeated demands for return. The court vacated portions of the enhanced damages and attorneys' fees awards for clarification.

Why it matters

The ruling reinforces that storage operators can be held liable for conversion, trespass to chattels and unfair trade practices when they condition the return of a tenant's goods on a liability release. It also clarifies limits on joint-and-several liability for trebled damages across multiple defendants.

The Court of Appeals upheld liability for conversion, trespass to chattels and unfair trade practices and affirmed the compensatory award, but vacated joint-and-several liability for trebled damages across all defendants. The enhanced damages and attorneys' fees portions were vacated and remanded for clarification, leaving final amounts unresolved.

The players

North Carolina Court of Appeals

The state's intermediate appellate court, which reviews decisions of the trial courts and issued the ruling affirming in part and vacating in part the judgment against the storage operators.

The details

Defendants, who operated and managed a storage facility in Moore County, over-locked the plaintiff's storage units, took possession of the inventory and retained it for several years despite repeated demands for its return. The trial court found them liable following a bench trial and awarded compensatory, punitive and trebled damages plus attorneys' fees.

Defendants retained the inventory for several years before the trial court ruled after a bench trial.
The Court of Appeals decision was published November 2, 2026.

Legal Context

The decision applies North Carolina's Unfair and Deceptive Trade Practices Act to self-storage operators who withhold tenants' property, a framework that has grown as storage facilities have become common repositories for household goods. The court's narrowing of joint-and-several liability for trebled damages sets a limit on how broadly such awards can be assigned across multiple defendants.

Renters of self-storage units in North Carolina may gain added protection from operators who attempt to withhold possessions in exchange for signing a liability release. The decision signals that such practices can lead to damages and fee awards against facility operators.

The takeaway

Renters who face a dispute over stored belongings should document inventory and written return demands, since those records supported the damages award in this case.