CVN Group, Inc. v. Delgado
95 S.W.3d 234 | Texas Supreme Court | 2002
What This Case Means for Subcontractors
CVN Group sued the Delgados over a home construction dispute and won an arbitration award that included a valid mechanic's lien. The Delgados challenged the lien in court, arguing the arbitrator lacked authority to decide lien validity. Texas Supreme Court ruled that parties can arbitrate mechanic's lien disputes, and courts cannot overturn arbitration awards on lien validity unless they violate fundamental public policy. This means your arbitration clause can cover lien disputes, and you don't have to litigate lien validity separately.
Key Takeaways
- •Include arbitration clauses in your contracts—they can cover mechanic's lien disputes, not just payment disagreements
- •If you arbitrate a lien claim and win, courts will enforce the award unless it violates basic public policy; don't expect judges to second-guess the arbitrator's decision
- •Make sure your arbitration agreement clearly states it covers 'claims, disputes or other matters' arising from the contract—broad language protects lien arbitration
The validity of CVN's lien claim was within the scope of its arbitration agreement with the Delgados, and the arbitrator's award does not violate public policy.
Frequently Asked Question
Can I arbitrate whether my mechanic's lien is valid, or do I have to go to court?
Yes, you can arbitrate lien validity if your contract includes an arbitration clause covering disputes. Once an arbitrator awards you a valid lien, courts must enforce it unless it clearly violates public policy. This can save you time and money compared to litigation.
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