PW Campbell Contracting Co. v. Yetter, A., 910 WDA 2024

PW Campbell Contracting Company (PWCC) contracted with Amanda and Jay Yetter in August 2021 to provide home improvements under a contract that included a fixed amount for some work and a variable amount based on cost plus 25% for construction.
Disagreements arose over workmanship and payments; PWCC stopped working in April 2023.
PWCC filed a mechanics’ lien claim for $77,292.29 but did not attach invoices or detailed documentation supporting this amount.
The Yetters filed preliminary objections, arguing the lien was untimely and that the contract was not for an "agreed sum," thus requiring a more detailed statement under the Mechanics’ Lien Law (MLL).
The trial court struck PWCC’s lien for failure to comply with the statutory requirements, specifically the lack of a detailed statement required for contracts that are not for an agreed sum.
PWCC appealed, contending they complied with MLL requirements and substantial compliance should suffice.

Issue	PWCC Argument	Yetter Argument	Held
Did the mechanics’ lien comply with MLL § 1503(5) requirements?	PWCC argued the contract framework displaying how charges are calculated sufficed as an "agreed sum," and attaching the contract documents met statutory requirements.	The Yetters argued the contract was not for an "agreed sum," so a detailed breakdown of labor/materials and prices was required and not provided.	The court held the contract was not for an agreed sum, so § 1503(5) did not apply; a detailed statement per § 1503(6) was required and missing.
Should substantial compliance with MLL § 1503(5) suffice?	PWCC contended that strict compliance is unnecessary and that identifying the contract terms constitutes substantial compliance.	The Yetters maintained that strict compliance is required for mechanics’ liens and that PWCC failed to meet the statutory threshold.	The court found strict compliance with the MLL is necessary and PWCC’s efforts did not satisfy the statutory mandate.
Was it error for the trial court to not allow amendment of the complaint?	PWCC argued in reply that they should have been allowed to amend their complaint.	Yetters noted this argument was not presented prior to reply, so it is waived.	The court held the amendment argument was waived due to failure to raise it earlier.

Denlinger, Inc. v. Agresta, 714 A.2d 1048 (Pa. Super. 1998) (discussing standards for sustaining preliminary objections in mechanics’ lien proceedings)
Terra Tech. Svcs., LLC v. River Station Land, L.P., 124 A.3d 289 (Pa. 2015) (scope of review and strict compliance with the Mechanics’ Lien Law)
R.A. Greig Equip. Co. v. Mark Erie Hosp., LLC, 305 A.3d 56 (Pa. Super. 2023) (purpose and scope of mechanics’ liens under the MLL)
Terra Firma Builders, LLC v. King, 249 A.3d 976 (Pa. 2021) (requirement for judicious adherence to MLL requirements)