Precision Framing Systems Inc. v. LuzuriagaAnnotate this Case
Henry and Deborah Luzuriaga contracted with a general contractor for the construction of a commercial building. The general contractor contracted with Precision Framing Systems, Inc. (Precision) for the framing, including the necessary trusses. And Precision contracted with Inland Empire Truss, Inc. (Inland) for the fabrication of the trusses. Precision never received full payment. Accordingly, it recorded a mechanic’s lien claim. Meanwhile, there was a problem with some of the trusses. After Precision had already recorded its mechanic’s lien claim, Precision and/or Inland came back to the site and repaired the trusses. Precision filed this action to foreclose its mechanic’s lien. Ms. Luzuriaga filed a cross-complaint. The trial court granted summary judgment against Precision on its complaint. It ruled that the mechanic’s lien claim was filed prematurely. Precision appealed, contending primarily that there was a triable issue of fact as to whether it had ceased to provide work, because: (1) “ceas[ing],” within the meaning of the statute, can be a gradual process; (2) the repair of the trusses was not part of Precision’s “work;” (3) there was evidence that Precision completed all of its work before it recorded its mechanic’s lien claim; and (4) there was evidence that the repairs were done by Inland. Henry Luzuriaga and the Luzuriagas’ bonding company cross-appealed. After review, the Court of Appeal affirmed, agreeing with the trial court that the evidence showed, beyond a triable issue of fact, that Precision had not yet “cease[d] . . . work” when it recorded its mechanic’s lien claim. This mooted the cross-appeal.