Bates & Associates, Inc. v. Providence Bank & Vision Ventures, LLC, ED106955

Bates & Associates (architect) contracted with Vision Ventures in Oct. 2013 to provide design, construction documents, and construction administration for a senior-care facility; total contract ≈ $325,000.
Vision had previously granted a deed of trust on the project property to Premier Bank; the loan, note and deed were later assigned to Providence Bank. Vision later filed Chapter 11.
Bates submitted a final invoice dated July 7, 2014 claiming $305,279.01 owed and filed a mechanic’s lien on the property on July 15, 2015. Providence foreclosed non-judicially on July 17, 2015 and obtained title.
Bates alleged additional architectural work occurred Jan–Mar 2015 (after it submitted a proposed supplemental agreement), and argued that those services extended the accrual date so its July 2015 lien was timely.
Trial court awarded Bates breach-of-contract damages against Vision but denied enforcement of the mechanic’s lien against Providence, finding (1) the Jan–Mar 2015 work was not performed under the original contract or a signed supplement and (2) the lien was untimely. Bates appealed.

Issue	Plaintiff's Argument (Bates)	Defendant's Argument (Providence/Vision)	Held
Whether Bates's architectural services were lienable under Mo. Rev. Stat. ch. 429	Services (including work on redesign proposals) were architectural services directly connected with the planned improvement and thus lienable even if construction hadn’t started	The 2015 work was not performed under the original contract or any executed supplement and was not "directly connected" to improvements, so not lienable	Work in Jan–Mar 2015 was not under the original contract or a signed supplement and did not produce plans directly tied to improvements; therefore not lienable
Whether the mechanic’s lien was timely (when did indebtedness "accrue")	Continued services in Jan–Mar 2015 meant the indebtedness did not accrue until Mar 23, 2015, so Bates’s July 15, 2015 lien was within the 6‑month filing window	The last completed work per Bates’s July 7, 2014 invoice fixed accrual on Jul 7, 2014, so the 6‑month window expired Jan 7, 2015 and the July 15, 2015 filing was untimely	Court held indebtedness accrued July 7, 2014 based on Bates’s own July 2014 invoice; lien deadline expired Jan 7, 2015; July 15, 2015 filing was untimely, so no lien attached

Ivie v. Smith, 439 S.W.3d 189 (Mo. banc 2014) (standard of review for bench trial)
United Petroleum Serv., Inc. v. Piatchek, 218 S.W.3d 477 (Mo. App. E.D. 2007) ("accrued" means when last labor performed or last material furnished)
Brentwood Glass Co. v. Pal’s Glass Serv., Inc., 499 S.W.3d 296 (Mo. banc 2016) (discusses accrual for lien purposes)
Altom Const. Co. v. BB Syndication Servs., Inc., 359 S.W.3d 146 (Mo. App. S.D. 2012) (partial/implemented plans can support a lien)
Patterson v. Rough Road Rescue, Inc., 529 S.W.3d 887 (Mo. App. E.D. 2017) (contract interpretation: give effect to parties’ intent)
Winters Excavating, Inc. v. Wildwood Dev., L.L.C., 341 S.W.3d 785 (Mo. App. S.D. 2011) (party seeking lien must prove statutory compliance)