most of the time a bank will put a stamp on a title if a loans has been taken out against it, it will most likely need a sig from the lien holder that its satisfied, + a letter of satisfaction of payment.

every car ive had a loan on, after it was paid off, the title came with all this crap.

Or if he owed money to someone and they went to court and the last owner did not show up, they can put a lien on the cars registration for the amount owed, and dmv collects the money for you, aka a lien.

wish you the best luck, sometime other peoples sh!t follows you around, and that sucks.