Westchester Commercial Division Justice Linda S. Jamieson issued a detailed Decision and Order in Camsan Inc. v. OPRA III LLC, Index No. 64814/2022 (and related actions), addressing multiple motions involving mechanic’s liens filed against a large residential construction project in Rye. The decision clarifies the application of New York’s Lien Law in the context of condominium developments and reaffirms the courts’ liberal approach toward lien enforcement.

Background

The case involves an expansive and complex construction project at 120 Old Post Road in Rye, now a condominium property. Numerous contractors and suppliers—ranging from general contractor Hudson Meridian Construction Group to smaller subcontractors like Camsan Inc., Valex Enterprises, and GFC Lighting—filed mechanic’s liens after allegedly not being paid for their work.

The property owner, OPRA III LLC (“OPRA”), moved to discharge all liens, asserting that they were facially invalid. OPRA argued that the liens (1) were filed against outdated or incorrect lot designations, (2) included sold units that were no longer owned by OPRA, or (3) were improper “blanket liens” against the entire condominium.

Multiple lienholders cross-moved to amend their liens nunc pro tunc to reflect only unsold units or those still owned by OPRA, and also sought court orders compelling OPRA to disclose ownership details.

Legal Analysis

Justice Jamieson rejected OPRA’s attempt to invalidate the liens wholesale, emphasizing several key principles of New York lien law:

  1. Liberal Construction of Lien Law: Citing Court of Appeals and Second Department precedent, the court reiterated that the Lien Law is remedial in nature and should be construed liberally to protect the rights of contractors and suppliers. Technical defects—such as overbroad property descriptions—do not necessarily invalidate a lien.
  1. Substantial Compliance Standard: The court found that the lienholders had substantially complied with the Lien Law. Even where a lien encompassed more property than appropriate, it could be enforced against the portion properly subject to the lien. Justice Jamieson cited E. Coast Mines & Materials Corp. v Golf Course Props. Co., 228 AD2d 545 [2d Dep’t 1996] as controlling authority.
  1. Doctrine of Laches Applies to Lien Challenges: The court found OPRA’s delay in raising challenges to the liens troubling. OPRA had participated in discovery and mediation for over a year without objecting to the liens’ validity. Justice Jamieson held that such delay prejudiced the lienholders, making OPRA’s position susceptible to a laches defense.
  1. Lien Validity Despite Condominium Conversion: Even though OPRA had sold some units, it still retained ownership of others at the time many liens were filed. Thus, consistent with Mussen v Franklin Square Assocs., V., LLC, 22 AD3d 1022, 1023 [3d Dep’t 2005], the liens remained valid as to the units still owned by OPRA and were not invalid on their face.

Ruling

In the Court’s Decision & Order, Justice Jamieson:

  • Denied OPRA’s motion to discharge the liens, except as to three defaulting parties.
  • Permitted all lienholders to amend their liens nunc pro tunc to properly identify unsold or OPRA-owned units.
  • Directed OPRA to disclose with particularity which units it currently owns and which it owned at the time each lien was filed.
  • Denied all requests for escrow or attorneys’ fees.

Conclusion

This ruling underscores the Commercial Division’s continued fidelity to the Lien Law’s remedial purpose. Owners seeking to challenge mechanic’s liens must do so promptly and cannot rely on hypertechnical defects—especially where the underlying labor and materials benefited the property. The decision is a reminder to contractors and owners alike that equity, timing, and a fair reading of the law all play crucial roles in lien enforcement.

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