Doors Acquisition, LLC v. Rockford Structures Construction Co., 39 N.E.3d 8

Rockford Structures contracted with Weitzel to build a hotel; D&P Chicago, Inc. was hired as drywall subcontractor.
D&P employed union members under a collective bargaining agreement and performed work on the project.
D&P was terminated; it allegedly owed wages and benefit contributions to union members for August–November 2007.
On January 10, 2008, Rockford Structures filed a sworn statement listing amounts due to suppliers and laborers, stating D&P was 100% paid; the union was not separately listed.
The union filed a subcontractor mechanics lien on March 6, 2008 claiming unpaid wages/benefits and sought foreclosure; Weitzel was unaware of the nonpayment at the time.
Trial court ruled in the union’s favor, ordering Weitzel to pay the lien amount; Weitzel appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the union’s lien is limited to the amount due to its immediate contractor	Union: lien may exceed if statute allows; not limited to immediate contractor.	Weitzel: owner may rely on section 5 sworn statement listing paid amounts; Bricks controls.	Lien limited to amount owed to immediate contractor; balance weighs in favor of owner.

Weather-Tite, Inc. v. University of St. Francis, 233 Ill. 2d 385 (Ill. 2009) (section 5 notice and owner payment duties; Sworn statements inform owner to retain funds)
Bricks, Inc. v. C&F Developers, Inc., 361 Ill. App. 3d 157 (Ill. App. 2005) (balances rights of owner and materialmen; owner protected when not aware of lower-tier claims)
A.Y. McDonald Manufacturing Co. v. State Farm Mutual Automobile Insurance Co., 225 Ill. App. 3d 851 (Ill. App. 1992) (third-tier subcontractor lien; distinguishable facts; owner’s noncompliance affects result)
Struebing Construction Co. v. Golub-Lake Shore Place Corp., 281 Ill. App. 3d 689 (Ill. App. 1996) (owner and contractor knowledge of plaintiff affects lien outcome)