John W. Goodwin, Inc. v. Fox

CLIFFORD, Justice,

with whom WATHEN, Chief Justice, joins, dissenting.

Because in my view Goodwin’s motion to amend the complaint to add the general contractor was correctly denied as to the lien claim, I respectfully dissent.

10 M.R.S.A. § 3255(1) (Supp.1993) provides in pertinent part:

The liens ... may be preserved and enforced by action against the debtor and owner of the property affected and all other parties interested therein, filed ... within 120 days after the last of the labor or services are performed or labor, materials or services are so furnished_

(Emphasis added.)

The liberal construction generally given the lien statute to effect its purpose does not apply to the time within which a lien action must be brought. Pineland Lumber Co. v. Robinson, 382 A.2d 33, 36 (Me.1978); Bellegarde Custom Kitchens v. Leavitt, 295 A.2d 909, 912 (Me.1972) (time within which lien must be brought is substantive and not waivable, and failure to bring action within statutory time precludes court from entertaining action).

Because the lien action secures the debt owed to the subcontractor by the general *1342contractor, Campbell, as the debtor is an essential party to the lien action. T.A. Napolitano Elec. Contractors v. Direnzo, 602 A.2d 1149, 1151 (Me.1992). There can be no cognizable lien action unless there is joinder of both the debtor and owner within the statutory time of 120 days. In this ease, because of the failure to join Campbell within 120 days of the last work performed, Goodwin’s lien action dissolved and cannot be revived by the amendment to add a party. See Bellegarde Custom, Kitchens, 295 A.2d at 912 (special lien right exists only during statutory period).

M.R.Civ.P. 15(c) (1991), in effect at the time, cannot be invoked to revive the expired action because the motion to amend had to be brought “within the period provided by law for commencement of the action against the party to be brought in by amendment.” This lien action had to be brought against Campbell within 120 days. It was not, and the motion to amend was properly denied.

I would affirm that part of the Superior Court judgment denying the motion to amend the complaint to add Campbell as a party to the lien action.