Predevelopment engineering services are lienable improvements: Supreme Court

Commercial Litigation

By Paul B. Porvaznik

Paul B. Porvaznik is an attorney at Davis, McGrath LLC and practices primarily in the areas of commercial litigation, landlord-tenant law, mechanic’s liens and post-judgment enforcement.

Posted November 30, 2015 2:50 PM

The Illinois Supreme Court recently reversed the 3rd District Appellate Court and found that an engineering firm’s predevelopment services supplied to an unfinished real estate project were still lienable even though the services didn’t physically alter the land or improve the property value.In Burke Engineering, Ltd. v. Heritage Bank of Central Illinois, 2015 IL 118955 (Nov. 19, 2015), the plaintiff was hired in April 2008 by a future property owner (Owner 2) who was in the process of buying the property from …

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