TX STATETexas Court of Appeals, 1st District (Houston)
1999

Bond v. Kagan-Edelman Enterprises

985 S.W.2d 253Texas Court of Appeals, 1st District (Houston) • Decided 1999Remanded

HOLDING

A subcontractor (Bond) and supplier (Gateway Lumber) sued a property owner (Kagan-Edelman) for unpaid work on a restaurant buildout. The owner had paid the general contractor (Irwin) after receiving notice of unpaid claims from the subcontractors. The Texas Court of Appeals ruled that property owners are liable to subcontractors for trapped funds and statutory retainage, and that subcontractors' liens attach to the owner's property interest, not just the lessee's. The case was remanded for trial, giving subcontractors a significant win on lien rights.

KEY FINDINGS

Lien Rights

Send written notice of your unpaid claims directly to the property owner, not just the general contractor. This notice triggers the owner's liability for funds they pay out afterward.

Retention

Your lien rights extend to the owner's fee interest in the property, giving you a stronger claim than relying solely on the lessee's leasehold interest.

FULL COURT OPINION