He is not a lienholder if there is no written security agreement giving him a security interest in the car and the right to possess: while you are correct that an oral (that is the better term than "verbal") agreement is enforceable, selling someone property (e.g. a car) with payments over time does *not* by itself create the right to repossess the property unless there is an actual security. All it creates is an agreement to pay certain amounts in exchange for a car. Rather, he certainly has the right to sue you for the money you owe him, if you are behind on payments, but that is his recourse: not to simply repossess. Rather, he has to sue you and get a monetary judgment in his favor, if you owe him money; then if not paid, he could convert that into a lien.Furthermore, he can't refuse payments--he has to accept them since his cause of action is for money. Or rather: he can refuse them, but can't use his own refusal as grounds to hold you in breach.