WV STATEWest Virginia Supreme Court
2021

Miller v. Wesbanco Bank, Inc. and Wesbanco Bank, Inc. v. Miller

West Virginia Supreme Court • Decided 2021affirmed in part, reversed in part, remanded

HOLDING

A West Virginia court ruled on a construction loan dispute between homeowners and a bank. The court held that lenders can condition fund advances on receipt of executed lien waivers and satisfactory inspections. The decision clarifies that multiple loan documents must be read together as one agreement, and parol evidence can explain ambiguous terms. For subcontractors, this means lenders have strong contractual grounds to withhold payment until lien waivers are provided.

KEY FINDINGS

Lien Waiver

Lenders can legally require executed lien waivers before releasing construction funds—this is enforceable under West Virginia law

Lien Rights

Multiple loan documents (promissory note, mortgage, construction agreement) are interpreted as a single transaction, so review all related paperwork together

Retention

Ambiguous loan terms can be clarified using parol evidence (oral testimony, emails, prior discussions), so document all communications with lenders about payment conditions

FULL COURT OPINION