National City Mortgage v. Bergman 

Illinois Appellate Court
Civil Court
Mechanics Lien Act
Citation
Case Number: 
No. 2-09-0934
Decision Date: 
Wednesday, October 20, 2010
District: 
2d Dist.
Division/County: 
Lake Co.
Holding: 
Reversed and remanded with directions.
Justice: 
BURKE
Section 7 of the Illinois Mechanics Lien Act does not require the inclusion of a statement of the contract completion date on a lien claim in order to be enforceable. Mechanics Lien Act must be strictly construed, as mechanics' liens were not recognized at common law or in equity but exist only by virtue of statutes. (HUTCHINSON and JORGENSEN, concurring.)