Reliance Universal, Inc. v. Deluth Construction Co.

The critical consideration in this case is whether a property owner (Northland Park) obtains the protection of R. C. 1311.05 against the mechanics’ lien of a materialman (Reliance) when the property owner pays a contractor (Deluth Construction) without specifically complying with the requirements of R. C. 1311.04. Reliance contends that Northland Park’s failure to secure a sworn statement from the contractor precludes Northland Park from defeating the lien. Northland Park, on the other hand, argues that an owner is not liable for any errors in a certificate of materialman unless the owner is…