Heidelberg Materials NE v. Blue Rock Construction, 875 EDA 2024

Blue Rock Construction was the general contractor on a property development project, subcontracting labor and materials through intermediaries to Heidelberg Materials Northeast, LLC (formerly Hanson Aggregates).
Heidelberg filed a mechanics’ lien to secure payment for unpaid labor and materials, asserting a final furnishing date that would render the claim timely under Pennsylvania law.
Blue Rock and Heidelberg entered a Joint Stipulation allowing Blue Rock to intervene and agreeing that the mechanics’ lien was valid, with Blue Rock explicitly waiving all defenses.
Blue Rock later sought discovery challenging the timeliness and validity of the lien and attempted to assert affirmative defenses, arguing the waiver was invalid.
The trial court denied Blue Rock’s discovery motions, dismissed its defenses, and granted summary judgment for Heidelberg, all relying heavily on the binding nature of the Joint Stipulation and waiver.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Denial of discovery into lien timeliness and stipulation	Waiver in joint stipulation bars defenses, no grounds for further discovery	Entitled to discovery on possible mistake or invalid stipulation, affecting lien timeliness	No abuse of discretion; waiver in stipulation is binding, no right to discovery
Procedural due process to challenge stipulation	Party bound by litigation waiver, no extra due process required	Must be allowed to challenge the validity of the stipulation in court	No authority supports right to undo prior stipulation; argument waived
Subject matter jurisdiction and waiver	Timeliness issue is a waivable defense, not a prerequisite to jurisdiction	Timeliness defect would deprive court of subject matter jurisdiction, not waivable	Lower court has jurisdiction, deadline issue is not jurisdictional; waiver upheld
Summary judgment on mechanics’ lien claim validity	No valid defense, all waivers in stipulation, no material factual dispute	Timeliness a genuine factual issue despite waiver, summary judgment not proper	No preserved defense, summary judgment for plaintiff affirmed

Terra Firma Builders, LLC v. King, 249 A.3d 976 (Pa. 2021) (Strict compliance required for mechanics’ lien remedies; some statutory defects incurable)
Osial v. Cook, 803 A.2d 209 (Pa. Super. 2002) (Parties may stipulate to facts or issues, with such stipulations binding)
Tyler v. King, 496 A.2d 16 (Pa. Super. 1985) (Concessions in stipulations are judicial admissions, not later contestable)