Clark Construction Co. v. Warren

760 So. 2d 677, 2000 La. App. LEXIS 1139, 2000 WL 593009
CourtLouisiana Court of Appeal
DecidedMay 15, 2000
DocketNo. 33,223-CA
StatusPublished
Cited by3 cases

This text of 760 So. 2d 677 (Clark Construction Co. v. Warren) is published on Counsel Stack Legal Research, covering Louisiana Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Clark Construction Co. v. Warren, 760 So. 2d 677, 2000 La. App. LEXIS 1139, 2000 WL 593009 (La. Ct. App. 2000).

Opinion

h STEWART, J.

This is an appeal by Clark Construction Company, Inc., (“Clark”), from a judgment denying its petition for- a writ of mandamus seeking cancellation of liens filed by subcontractors in connection with the construction of a Wal-Mart Supercenter (the “Supercenter”). Because it appears that the trial court erred in denying the petition for the writ of mandamus without first addressing other pending issues which may warrant the relief sought by Clark, we hereby reverse that portion of the judgment denying the writ of mandamus as to those defendants against whom Clark asserted additional grounds for relief, and we remand the matter to the trial court for further proceedings to address the pending issues.

FACTS

On October 15, 1997, Wal-Mart Stores, Inc., (“Stores”) contracted with Clark, a general contractor, for construction of a Supercenter on Pines Road in Shreveport, Louisiana. A performance bond filed by Clark in connection with the construction project names Stores as the project owner. The bond was filed in the mortgage records of Caddo Parish on November 12, 1997. A notice of contract between Clark and Stores was recorded on December 19, 1997.

The property on which the Supercenter was to be constructed was purchased on October . 31, 1997 by Wal-Mart Stores, East, Inc., (“East”). Subsequently, Wal-Mart Real Estate Business Trust (“Trust”) purchased the property from East on November 25,1997.

On August 17, 1997, Clark filed a “Certificate of Substantial Completion” of the project. This notice was recorded in the Caddo Parish mortgage records. Over thirty days after the filing of the notice of completion, the defendants, subcontractors on the project, filed liens under the provisions of the Private Works Act, La. R.S. 9:4801 et seq., on the dates listed:

Curbs, Inc. Sept. 17, 1998
Mohr & Associates, Inc. Sept. 17, 1998
|2Prime Services, Inc. Sept. 18, 1998
TXl Operations, L.P. Oct. 2,1998
Murphy Bros. Tracking, Inc. Oct. 7,1998
R.B. Everett & Company Oct. 9,1998
Alto Concrete Floors, Inc. Oct. 9,1998
Con-Equip, Inc. Oct. 9,1998
Anderson Machinery Company Oct. 9,1998
Alvin Equipment Company Oct. 9,1998
Gifford Hill & Company Oct. 14,1998

Clark then sought a writ of mandamus ordering cancellation of these liens from [679]*679the public record. Clark’s primary contention in its petition was that the defendants’ liens were untimely filed. Clark asserted that in accordance with La. R.S. 9:4822, the defendants were required to record their liens within thirty days of the recor-dation of the notice of substantial completion.1 Since the notice was recorded on August 17, 1998, the defendants should have asserted their claims prior to September 16, 1998. Clark also raised other grounds for relief in its petition and amended petition. Against Prime Services, Inc., Con-Equip, Inc., Anderson Machinery, and Alvin Equipment Co., Clark asserted the failure to provide notice of an equipment lease as required by La. R.S. 9:4802(G) as grounds for cancellation of their liens. Against Mohr & Associates, Inc., Clark asserted the failure to provide notice in accordance with La. R.S. 9:4802(A)(5)(b), which requires prime consultants to give written notice within thirty working days after the date of employment.

The defendants’ primary argument against Clark was that the thirty day period for filing their liens did not apply since there was no recorded notice of | ¡¡contract between Clark and the “owner” as required by La. R.S. 9:4811.2 The defendants asserted that the “owner,” as defined by La. R.S. 9:4806, is the record owner of the immovable.3 Here, Clark did not contract with either record owner, East or Trust.

A hearing was scheduled for February 1, 1999. Clark’s memorandum in support of its petition for a writ of mandamus includes the following paragraph:

In order to avoid the expense of bringing in witnesses from out of town, and with the belief that the Court’s decision on the more pervasive issue of whether the liens were timely filed may render moot some of the other issues, the parties request that the Court consider only the issue of whether the liens were timely filed at this time. With the Court’s indulgence, the parties will reserve all other issues for a consideration at a later date.

The issue of whether the liens were timely filed was submitted to the trial court on the date of the hearing on the basis of the parties’ memoranda and stipulations. In a judgment rendered February 25, 1999, the [680]*680trial court concluded that the notice of contract was not signed by the record owner of the property as required by La. R.S. 9:4811 and found that all liens or privileges filed within sixty days .of August-12, 1998, the date of substantial completion, were timely. The trial court then, went on to deny the writ of mandamus for all claims or privileges filed on or before sixty | ¿days from August 12, 1998, and to grant the writ of mandamus as to all claims filed more than sixty days after that date.4

Thereafter, Clark filed a motion for a new trial seeking to have the trial court limit its ruling to the issue of timeliness of the liens. In support of its motion, Clark included its memorandum in support of the petition for writ of mandamus which explained that the parties desired to limit the February 1, 1999 hearing to the issue of. timeliness and reserve the remaining issues for consideration at a later date. Clark also included a letter to the trial court dated January 28, 1999, discussing the scheduled hearing, the parties’ joint stipulation, and the parties agreement to limit the hearing to the issue of timeliness. No memorandum in opposition to Clark’s motion for a new trial is included in the record. The trial court denied Clark’s motion, and this appeal by Clark followed.

DISCUSSION

Clark asserts that the trial court erred in denying the writ of mandamus and asks this court to remand the case for further proceedings on the merits. Clark also asserts that the trial court erred in determining that the liens filed within sixty days from August 12, 1998 were timely. Curbs, Inc. ■ (“Curbs”), filed a brief agreeing with Clark’s assertion that the trial court erred denying the' writ of mandamus since only the timeliness issue was to be decided. Murphy Bros. Trucking, Inc. (“Murphy”), concurs in Curbs’ arguments. We note that Clark has- no other defenses against either Curbs or Murphy other than the timeliness of their liens. Mohr & Associates, Inc. (“Mohr”), against whom Clark asserted another basis for Cancellation of its lien, argues that the trial court correctly denied the writ of mandamus as to those liens filed within sixty days from the date of substantial | ^completion. Mohr asserts that denial was proper due to the confusion created by the ownership issues and the 'failure of Clark and the Wal-Mart entities to strictly comply with the requirements of the Private Works Act. Mohr also asserts that because Clark never engaged in a construction contract with the record owner, Clark cannot demand cancellation of the liens.

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760 So. 2d 677, 2000 La. App. LEXIS 1139, 2000 WL 593009, Counsel Stack Legal Research, https://law.counselstack.com/opinion/clark-construction-co-v-warren-lactapp-2000.