City Electric Supply Co. v. Arch Insurance Co., 119 N.E.3d 735

City Electric Supply (CES) supplied materials to subcontractor Michael Franciosi and recorded a mechanic's lien in Norfolk County for $283,056.54.
General contractor Tocci recorded a target lien bond under G. L. c. 254, § 14, naming Arch Insurance as surety, which dissolved the recorded lien on the land records.
CES sued Franciosi and Arch in Superior Court within the statutory period to enforce the target lien bond but did not record an attested copy of its complaint in the registry of deeds within 30 days of filing; it later recorded the complaint after Arch objected.
Arch moved for summary judgment, arguing that G. L. c. 254, § 5 (which requires recording an attested copy of a complaint to enforce a lien) applies and therefore CES’s suit failed for lack of recording.
The Superior Court granted Arch’s motion; CES appealed directly to the Supreme Judicial Court.
The SJC reviewed whether § 14 requires recording an attested copy of the complaint as a prerequisite to enforcing a target lien bond and vacated the summary judgment, holding § 14 contains no such recording requirement.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a claimant enforcing a target lien bond under G. L. c. 254, § 14 must record an attested copy of the complaint in the registry of deeds within 30 days	CES: § 14 does not include that requirement; § 14 governs enforcement and contains its own procedural rules	Arch: § 14 must be read with § 5, and § 5’s recording requirement applies to enforcement actions, including § 14 actions	Held: No. § 14’s text contains no such requirement; courts will not read § 5’s recording mandate into § 14 because the omission is meaningful and would create surplusage

NES Rentals v. Maine Drilling & Blasting, Inc., 465 Mass. 856 (2013) (explains nature and enforcement of lien dissolution/target bonds)
National Lumber Co. v. United Cas. & Sur. Ins. Co., 440 Mass. 723 (2004) (discusses mechanic's lien statutory scheme and recording effects)
National Lumber Co. v. LeFrancois Constr. Corp., 430 Mass. 663 (2000) (emphasizes land-records notice purpose of lien statute)
Tremont Tower Condominium, LLC v. George B.H. Macomber Co., 436 Mass. 677 (2002) (filing notice is the act that creates a mechanic's lien)
Golden v. General Bldrs. Supply LLC, 441 Mass. 652 (2004) (requires exact statutory compliance for lien creation, perfection, enforcement)
Valentine Lumber & Supply Co. v. Thibeault, 336 Mass. 411 (1957) (under earlier statutory scheme, recording complaint was required to enforce a lien bond)
Modern Cont. Constr. Co. v. Lowell, 391 Mass. 829 (1984) (court cannot supply statutory omissions)