Williams & Works, Inc. v. Springfield Corporation
Supreme Court of Michigan
293 N.W.2d 304 (1980)
Springfield Corporation (defendant) hired Williams & Works (W&W) (plaintiff) to perform engineering services for a planned apartment complex; W&W did that work off-site before any construction began. Springfield then bought the land from Kelly Mortgage (Kelly), giving Kelly two mortgages that were recorded, and construction began about a month later. After the project failed, W&W sued to foreclose its mechanics' lien, arguing it outranked the mortgages because the engineering was performed before they were recorded. The trial court and court of appeals sided with W&W, and Kelly appealed.
Whether a mechanics' lien for off-site, pre-construction engineering services takes priority over a mortgage recorded after those services are performed but before on-site construction begins.