BAILMENT 281 
such construction. In addition, when the stock 
has been left for some special service, as that of a 
trainer, or of a veterinarian, a lien is frequently 
provided for the payment of those services. 
(§§ 79-83.) 
A lien may be created by contract. A con- 
tract to pay before moving stock creates a lien.?? 
Where the contract for the keep of stock creates a 
lien, it operates on all; not upon a number pro- 
portional to the amount due.*? A contracted to 
care for the cattle of B for five months; the con- 
tract was canceled in two months by B, who 
claimed that the cattle were not well kept. It 
was held by the court that A had a lien only for 
the payment of the care for the two months.*4 
234. General Liens. A specific lien is recog- 
nized in cases where the bailee has expended labor 
and material for the betterment of the thing 
bailed. The tailor has a lien on the clothes which 
he made from the cloth left by the bailor, etc. The 
lien of veterinarians, agisters, blacksmiths, and 
livery keepers has frequently been recognized 
either in common law or statutes. In each of these 
cases the lien attaches to the special item, or items 
in the possession of the bailee, for that specific 
account. General liens, that is the holding of any 
property for the payment of an account not related 
to the article directly, are not favored in law, and 
when found they are very strictly interpreted by 
31 Cummings v. Harris, 3 Vt. 8S. W. 1023; Yearsley v. Gray, 
244, 23 Am. Dec. 206. 140 Pa. St. 238, 21 Atl. 318; 
32 McCoy v. Hock, 37 Ia. 436. Hensel v. Noble, 95 Pa. St. 345. 
33 Barse Live Stock Com. Co. 84 Powers v. Botts, 58 Mo. 
v. Adams, 2 Ind. Ter. 119, 48 App. 1. 
