Feltner v. Jung

8 Va. Cir. 137, 1985 Va. Cir. LEXIS 54
CourtClarke County Circuit Court
DecidedAugust 27, 1985
DocketCase No. (Chancery) 2488
StatusPublished
Cited by1 cases

This text of 8 Va. Cir. 137 (Feltner v. Jung) is published on Counsel Stack Legal Research, covering Clarke County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Feltner v. Jung, 8 Va. Cir. 137, 1985 Va. Cir. LEXIS 54 (Va. Super. Ct. 1985).

Opinion

By JUDGE ROBERT K. WOLTZ

At issue is the validity of a mechanic’s lien filed by the complainant general contractor (Feltner) against properties owned by the primary defendants (Jung) under the provision of Sections 43-3 and 43-4, et seq.

September 16, 1983, Feltner filed a memorandum for mechanic’s lien for labor and materials in the construction of an indoor horse arena with bleacher accommodations and for construction of stalls in an existing barn and corn crib, claiming $55,388.80 was due therefor. The memorandum further disclosed that the arena was on the Locksley tract containing approximately 340 acres on Locksley Farm and that the stalls for the existing barn and corn crib related to the Glen Owen tract containing approximately 115 acres of Locksley Farm. These two tracts were conveyed to the owners in the same deed but as two separate parcels separately described. Inferentially the two parcels are contiguous.

In March, 1983, Feltner contracted with Jung to build the arena on the Locksley tract and commenced work on it. Before its completion, by separate contract in June Feltner contracted with Jung to build the horse stalls on the Glen Owen tract. Later, but timely, Feltner filed the above memorandum of lien.

Subsequently*, but also timely, Feltner filed a bill to i enforce mechanic's lien against the owners, joining three deed of trust holders. At least two of these deeds [138]*138of trust were liens against both tracts; this is unclear as to the third. The bill was to enforce mechanic's lien against the Locksley tract only, in the amount of $52,401.75 for work done in constructing the arena. Thereafter on objection of Jung the mechanic's lien on the Glen Owen tract was, without objection of Feltner, ordered to be released. It appears from Feltner's pleadings that before filing his bill to enforce he credited a sufficient portion of a payment from Jung to discharge the Glen Owen construction claim in full. Jung also filed a motion to declare the mechanic's lien invalid and for release of the Locksley tract from it because the memorandum of lien was not based solely on the contract for the construction on the Locksley parcel, sought a single lien on two separate parcels for work on each stemming from separate contracts, and, without effort at apportioning the two claims between the two parcels, sought to burden both parcels with the total of the claims emanating from the separate contracts, thereby setting up the issue.

A mechanic's lien is a creature of statute. Sergeant v. Denby, 87 Va. 206 (1890). Not only is the lien dependent on statute but the jurisdiction of the court as well "and not upon equitable or ethical rules." Feuchtenberger v. Williamson, 137 Va. 578 (1923). While the statutory provisions as to enforcement of mechanic's liens are liberally construed, "ftjhere must be a substantial compliance with the requirements of that portion of the statute which relates to the creation of the lien. . ." Francis & Co. v. Hotel Rueger, 125 Va. 106 (1919); Bristol Iron and Steel Co. v. Thomas, 93 Va. 396, 400 (1896), says "strict compliance" with statute in order to perfect the lien. Furthermore, "[t]he object of the law is to give to those who by their labor and materials, have enhanced the value of the building or structure, the security of a lien thereon to the extent they have added to its value, but not to give a lien therefor upon property not benefited thereby." Gilman v. Ryan, 95 Va. 494 (1898). The beneficent object is similarly set out in Bristol Iron and Steel Co. v. Thomas, supra. Finally, though a mechanic's lien is the creature of statute, "(ijt must have its foundation in contract." Sergeant, supra.

While the object of the mechanic's lien statute is entirely just, the statute affords an extraordinary procedure whereby without the consent or prior knowledge [139]*139of or prior notice to the property owner and others, if any, having an interest in the property and without prior judicial determination of their rights a lien may he placed upon the property, vitally affecting those rights. This is sufficient basis for the principle noted above that the statute as it relates to the creation of a mechanic’s lien must be substantially or even strictly complied with.

Where a mechanic’s lien is filed, the claim made in it in relation to the number of contracts and number of parcels of land involved can give rise to at least four readily apparent situations: first, a single contract for construction on a single parcel; second, separate contracts for construction on a single parcel; third, a single contract for construction on multiple parcels; and fourth, separate contracts for construction on multiple parcels. The first two situations are unrelated to the problem in the present case and can be disregarded. The development of the law on the latter two is related to the issue here.

The third situation is exemplified by Sergeant v. Denby, supra, where there was a single contract to construct for one entire price two houses on two separate lots. A joint or blanket mechanic’s lien was filed against both parcels, the Court noting that the lien must be founded in contract and correspond to the contract. The contract being one and relating to both parcels as an entirety, as between the lienor and the owner the blanket lien was held to be good as it was in effect for one piece of work though distributed over two parcels. Weaver v. Harland Corp., 176 Va. 224 (1940), sets forth the same rule but found the single mechanic’s lien invalid where the rights of third parties were involved and there was no specific amount of claim assigned to specific individual parcels. See also Wallace v. Brumback, 177 Va. 36 (1941), where under one contract for construction multiple liens had been filed on individual lots and holding that the liens had not been perfected in accordance with statute as some of the lots had been sold. In similar vein as to blanket liens are PIC Co. v. First Union Bank, 218 Va. 915 (1978), and United Virginia Mortgage Corp. v. Haines Paving Co., 221 Va. 1047 (1981).

Closer to the case at bar is Gilman v. Ryan, supra, where the statute as then written required an account [140]*140of the work or materials, the prices therefor, the payments made and the balance due to be filed in order to establish a mechanic’s lien. Though each of the three mechanic lienors had a single contract as to building different houses on different parcels, because of different estimates as to different houses none of the contracts was for an entire or blanket price for all the work or materials to be supplied. The accounts the lienors filed named all the houses involved but lumped them all together as to contract price and balance due for the work or materials. While expressly acknowledging the rule in Sergeant as to the validity of a mechanic’s lien on different parcels where the contract provided one entire price for the whole work to be done, these accounts were held not to be in compliance with the statute and the liens invalid, the case stating:

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14 Va. Cir. 344 (Clarke County Circuit Court, 1989)

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Bluebook (online)
8 Va. Cir. 137, 1985 Va. Cir. LEXIS 54, Counsel Stack Legal Research, https://law.counselstack.com/opinion/feltner-v-jung-vaccclarke-1985.