JM Properties of W. Palm Beach, Inc. v. Fort Dallas Truss Company, LLC
A truss fabricator contracted with a replacement general contractor to design, manufacture, and deliver trusses; when the contractor failed to pay the 50% due upon completion of shop drawings, the fabricator recorded a construction lien and sued for breach of contract and lien foreclosure. The Fourth DCA affirmed the finding that the fabricator was a 'materialman' under section 713.01(20) because it manufactured and delivered materials and performed no on-site labor, but reversed the lien recovery because the trusses were never delivered and thus no 'improvement' of permanent benefit to the property occurred under section 713.01(15).
Key facts
- JM Properties, a truss fabricator, contracted with Fort Dallas Truss Company, a replacement general contractor, to design, manufacture, and deliver trusses for a construction project.
- Fort Dallas failed to pay 50% of the contract price due upon completion of shop drawings; JM Properties recorded a construction lien and sued for breach of contract and lien foreclosure.
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Why it matters
The opinion is a useful weapon for owners and contractors defending against liens by fabricators whose specially fabricated materials were never delivered or incorporated: completion of shop drawings alone does not… — full analysis with a trial
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