Edgerock Development, LLC v. C.H. Garmong & Son Inc

Summary

The court held that construction liens secure only the debt attributable to improvements directly benefiting the property against which each lien is asserted, requiring reduction or invalidation of liens that improperly charge one owner's property for another owner's improvements. It also held that construction-lien priority relates back to the date work began, making the contractors' liens generally senior to First Bank's mortgage, except for the portion of the loan used to satisfy an earlier construction lien. The court affirmed in part, reversed in part, and remanded for a revised judgment; it also declined to apply equitable subrogation.