Two subcontractors registered construction liens for unpaid work on a residential construction project.
The court considered whether the liens were preserved within the 45‑day statutory period under the Construction Lien Act based on the date of last supply of services or materials.
After reviewing the evidence, the court found that neither subcontractor proved that qualifying work occurred within the preservation period, and both liens had therefore expired.
The subcontractors also advanced alternative claims for restitutionary quantum meruit against the owners.
The court rejected those claims, holding that unjust enrichment remedies against owners would undermine the statutory construction lien regime where contractual relationships and lien remedies already governed the parties’ rights.
