Schell, S. v. Murphy, R., 153 A.3d 379

On January 15, 2016, Samuel Schell (doing business as Quali-Te-Lawn) filed a mechanics’ lien claim against Richard V. Murphy, the sole record owner of a residential property in Bedford County, alleging work performed under a July 31, 2015 contract and claiming $17,484.23 plus interest and costs.
Schell alleged he began work August 18, 2015, was directed to leave the premises November 20, 2015, and that substantially all improvements were complete by then.
Murphy filed preliminary objections arguing the claim must be dismissed because Mrs. Murphy (the owner’s wife) was a party to the home‑improvement contract but not an owner of the property, and thus an indispensable party who could not be joined in a mechanics’ lien action.
The trial court sustained the preliminary objections, concluding Mrs. Murphy had a vital, indispensable interest and that her absence would violate due process, and dismissed Schell’s complaint.
On appeal, the Superior Court examined the statutory requirements for a mechanics’ lien and whether naming the record owner satisfies the statute when a non‑owner spouse is a contract party.
The Superior Court reversed, holding the Mechanics’ Lien Law requires naming the owner or reputed owner only, and a non‑owner spouse who was a party to the contract is not an indispensable party to the lien action; contract remedies remain available separately.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a non‑owner spouse who is a party to the underlying contract is an indispensable party to a mechanics’ lien action against the record owner	Schell argued the statute requires naming the owner/reputed owner only; he sued the record owner and may pursue the lien without joining the non‑owner spouse	Murphy argued Mrs. Murphy, as a contract party, has indispensable rights and must be joined; because she is not an owner she cannot be joined in a lien claim, so complaint must be dismissed	The court held the non‑owner spouse is not an indispensable party to a mechanics’ lien action; naming the record owner satisfies the statute and dismissal was improper

Bricklayers of W. Pennsylvania Combined Funds, Inc. v. Scott’s Dev. Co., 90 A.3d 682 (Pa. 2014) (mechanics’ lien law protects prepayment of labor/materials and provides statutory security independent of contractual remedies)
Matternas v. Stehman, 642 A.2d 1120 (Pa. Super. 1994) (discussing the protective purpose of the Mechanics’ Lien Law)
Brann & Stuart Co. v. Consol. Sun Ray, Inc., 253 A.2d 105 (Pa. 1969) (mechanics’ lien is purely statutory and its requirements must be strictly followed)
Wyatt Inc. v. Citizens Bank of Pennsylvania, 976 A.2d 557 (Pa. Super. 2009) (a mechanics’ lien proceeding is distinct from a breach of contract action and not a vehicle to adjudicate unliquidated contract damages)