Heidelberg Materials v. IPT Allentown
1042 EDA 2024
Pa. Super. Ct.Apr 14, 2025Background
- The case involves construction of three warehouses across adjacent parcels in Lehigh County, Pennsylvania, with two parcels owned by IPT entities and one by IPT II, all constructed by Blue Rock Construction as general contractor.
- Heidelberg Materials (Appellant), a subcontractor, provided asphalt, labor, and materials for parking lots and entrances and filed three identical mechanics’ liens (each for the total contract amount) against the three properties.
- Blue Rock intervened, posting a bond to cover all three liens, and litigation ensued over lien validity and procedure under the Mechanics’ Lien Law of 1963.
- The trial court granted summary judgment for Appellees (IPT entities and Blue Rock), finding Heidelberg’s failure to apportion the lien amount among the three parcels violated statutory requirements.
- Appellant requested to amend its liens to properly apportion the amounts, but the trial court did not address this request; appellants appealed the summary judgment ruling.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did Appellant fail to comply with the Mechanics’ Lien Law by filing three liens, each for the full amount? | No violation; one contract for all work and amount could not be partitioned at lien filing time. | Yes; law requires apportionment between parcels that are not a single business plant. | Appellant erred but court should address amendment request before striking lien. |
| Was summary judgment appropriate before considering Appellant's request to amend liens? | Court must consider request to amend under § 1504 before granting judgment. | Claims were noncompliant and should be stricken as improperly filed. | Error to not address amendment; summary judgment reversed and remanded. |
| Does the Mechanics’ Lien Law permit amendment to apportion claims post-filing? | Yes; amendments allowed if aggregate amount is unchanged and no prejudice. | Not directly challenged, but opposed since original claims were procedurally defective. | Law allows amendment if no exceptions apply and no prejudice results. |
| Does posting a single bond to discharge liens affect Appellee’s challenge of lien procedure? | Blue Rock waived defect arguments by agreeing to the bond and stipulated procedure. | No waiver; procedural defects remain fatal to claims. | Not addressed as ruling turned on amendment issue. |
Key Cases Cited
- Terra Firma Builders, LLC v. King, 249 A.3d 976 (Pa. 2021) (explains that mechanics' liens are statutory remedies requiring strict compliance with statutory procedure)
- Summers v. Certainteed Corp., 997 A.2d 1152 (Pa. 2010) (sets forth standard for grant/review of summary judgment)
- Zeigler Lumber & Supply Co. v. Golden Triangle Development Co., Inc., 326 A.2d 524 (Pa. Super. 1974) (section 1504 to be liberally construed in favor of amendment of lien claims)