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4th DCANovember 4, 2026Reversed and Remanded⭐ Notable

Coastal Building Contractors, LLC v. Calixte

Case No. 4D2025-2593

A subcontractor recorded a claim of lien within 90 days of actual completion, but the lien misstated the completion date so that it appeared facially untimely; later amendments were recorded after the 90-day window. The trial court granted summary judgment invalidating the lien and awarded the homeowners $80,000 in fees. The Fourth DCA reversed, holding that timeliness turns on the actual date of final furnishing, not the date recited in the lien, and that the misstatement must be evaluated under section 713.08's safe-harbor provisions for errors that do not prejudice or adversely affect the owner.

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Key facts

  • Coastal Building Contractors, a subcontractor, recorded a claim of lien within 90 days of actual completion, but the lien contained a misstated completion date that made it appear facially untimely on its face.
  • The homeowners (Calixte) sought to invalidate the lien based on the erroneous completion date; the trial court granted summary judgment in their favor and awarded $80,000 in attorney's fees.
  • +2 more key facts with a free trial

Why it matters

This opinion gives construction lien practitioners a clear, citable framework: a facially defective completion date does not automatically defeat a lien, and courts must separately analyze whether the specific error… — full analysis with a trial

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