State-by-State Lien Matrix

 

State

Bonding Over Lien Permitted?

Time Restraints

Value of Bond

Required

Notice Requirements

Miscellaneous Issues

Anti-Advance Lien Waiver Statute?

Alabama

Yes

Upon notification by the court of the security transfer, lien claimant has ten days to challenge the sufficiency of the bond amount or the surety.  The court’s determination is final.[1]

 

Lien claimant must take action “within six months after the maturity of the entire indebtedness.”[2]

The value of the bond must equal the “amount demanded in such claim of lien plus interest thereon at eight percent per year for three years plus $100.00.”[3]

None

May recover attorney’s fees.[4]

No[5]

Alaska

Yes

None specific to the time on which a bond claim may be made; however, a lien will only bind real property for six months after the claim of lien is recorded, unless an action is commenced in the proper court within that time or six months after the recording of an extension notice.[6]

150% of the claim amount[7]

None

None

Yes.  Party may waive lien rights for work or materials furnished up to that date.[8]  However the waiver “may not relate to labor, materials, services, or equipment furnished after the date the waiver is signed by the claimant.”[9]  Laborers may not waive their lien rights, however.[10] 

Arizona

Yes

Suit must be commenced within six months after recording of bond.[11]

 

Lien claimant must name principal and surety as parties to lien foreclosure suit within six months of recording of lien or 90 days of receiving bond notice, whichever is longer.[12]

150% of the claim amount[13]

Lien claimant must be served within a reasonable time.[14]

May recover attorney’s fees.[15]

No.  Party waiving lien rights must execute a waiver and release form.[16]

Arkansas

Yes

Lien claimant must challenge the bond within three days of receiving notice.[17]

 

Lien claimant must take action on the bond within 15 months after recording of lien.[18]

200% of the claim amount.[19]

The circuit clerk or other officer before whom the bond is filed must notify the lien claimant of the filing of the bond.[20]

May recover attorney’s fees.[21]

No

California

Yes

Lien claimant must take action on the bond within six months of the recording of the lien release bond.[22]

150% of the claim amount.[23]

Must provide notice by certified or registered mail.  Failure to provide notice will toll the statutes of limitations.[24]

May not recover attorney’s fees in an action on a bond absent a direct contract between the claimant and the owner providing for attorney fees.[25]

Yes.[26]

Colorado

Yes

Lien claimant must take action on the bond within six months of the completion of work.[27]

150% of the claim amount, plus costs[28]

None

Must be approved by judge.[29]

No[30]

Connecticut

Yes

Lien claimant must take action on the bond within one year of the lien being perfected.[31]

Claim amount, plus interest and costs.[32]

Judge shall order reasonable notice be given.[33]

Must be approved by judge.[34]

 

May recover attorney’s fees.[35]

Yes[36]

Delaware

Yes.

The security posted in lieu of cash may, upon cause shown and upon petition of any party after notice and hearing, be decreased in amount or exonerated by the Court.[37]

The amount of the bond must be approved by the court, but the amount approved may not be less than the amount equal to the amount of the claim.[38]

None

Must be approved by court.[39]

Yes.[40]  May only waive right to file lien with or after payment.[41]

District of Columbia

Yes

Lien claimant must voice their objection to bond approval within two days of notice.[42]

 

Claim amount, plus interest and costs.[43]

Lien claimant must receive two days notice prior to motion seeking bond approval.[44]

Bond must be filed with two or more sureties.[45]

 

The filing of the bond must be approved by court.[46]

No[47]

Florida

Yes

Lien claimant must take action on the bond within one year of the lien’s recording.[48]

Claim amount and interest for three years, plus $1,000 or 25% of the claim amount, whichever is greater.[49]

Upon the filing of the bond, the clerk will mail a copy of the certificate showing the transfer of the lien to the bond.[50]

May recover attorney’s fees.[51]

Yes.  Lien rights may not be waived in advance.  Lien rights to labor, services, or materials already furnished may be waived, however.[52]

Georgia

Yes

Lien claimant must take action on the bond within one year of the lien’s recording.[53]

200% of the claim amount.[54]

Must provide notice by certified, registered, or statutory overnight mail within seven days of filing bond.[55]

None

Yes[56]

Hawaii

Yes

Lien claimant must take action on the bond within three months of the lien’s recording.[57]

 

200% of the claim amount.[58]

None

Attorney fees may be awarded by the court.[59]

No[60]

Idaho

Yes

Lien claimant must take action on bond within six months of lien’s recording.[61]

150% of the claim amount.[62]

Must provide notice at least two days prior to the hearing.[63]

May recover attorney’s fees.[64]

 

Must be approved by court.[65]

No[66]

Illinois

No

None

None

None

None

Yes[67]

Indiana

Yes

May not bond over lien until foreclosure action has commenced.[68]

 

Lien claimant must file a complaint to enforce a lien within one year of the lien’s recording.[69]

Claim amount, plus costs and attorney’s fees.[70]

None

May recover attorney’s fees.[71]

 

Must be approved by the court.[72]

Yes[73]

Iowa

Yes

Lien claimant must bring action on bond within two years and ninety days after materials were furnished or labor was performed last.[74]

200% of the claim amount.[75]

None

Must be approved by the clerk.[76]

No[77]

Kansas

Yes

Lien claimant must bring action on bond within one year of lien’s recording[78]

At least the amount of the contract price.[79]

None

Must be approved by the court.[80]

Yes[81]

Kentucky

Yes

Must bond over lien prior to judgment enforcing the lien.[82]

 

Lien claimant must take action on bond within one year of lien’s recording.[83]

200% of claim amount.[84]

None

Must be approved by the clerk.[85]

Yes[86]

Louisiana

Yes[87]

Lien claimant must take action on bond within one year of the termination or completion of work.[88]

125% of the claim amount.[89]

Must provide notice by certified mail.[90]

May recover attorney’s fees.[91]

No

Maine

Yes

Bond must be paid out within 30 days of final judgment.[92]

Claim amount, plus costs.[93]

Judge issues notice at least 10 days prior to hearing on whether the lien shall be released in favor of a bond in the amount determined by the court to be potentially owed.[94]

Must be approved by the court.[95]

No

Maryland

Yes

The right to enforce a lien will expire at the end of one year from the day on which the petition to establish the lien was first filed.  During this time, the lien claimant may file a petition to execute on a bond given to release the lien.  If an action is filed within that time period, the bond will remain in force until the conclusion of that action and, thereafter, only in accordance with a Court order.[96]

Amount determined by the court.[97]

None

Must be approved by the court.[98]

Yes[99]

Massachusetts

Yes

Lien claimant must take action on bond within 90 days of receiving notice of bond.[100]

Claim amount[101]

Notice of recording the bond must be given to the lien claimant by serving a copy of the notice and a copy of the bond.[102]

Specified, statutory form to use for the bond.[103]

Yes[104]

Michigan

Yes

Lien claimant has 10 days to appeal the sufficiency of the surety on the bond following notification.[105]

200% of the claim amount.[106]

County clerk must notify each lien claimant within 10 days after the bond’s filing.[107]

None

Yes[108]

Minnesota

Yes

After the commencement of an action by either the lien claimant or the owner, anyone with an interest in the property may apply to the court for a release.[109]

 

Lien claimant must take action on bond with one year of lien’s filing.[110]

The value of the bond set by the court shall not be less than the aggregate of the following:  (1) the amount claimed in the lien statement, (2) $18 for every $100 or fraction thereof, to cover interest, (3) the probable disbursements in an action to enforce the claim for which the lien statement was filed, (4) an amount not less than double the amount of attorneys' fees allowed upon the foreclosure under section 582.01, to cover any allowance the court may make upon the trial for costs and attorneys’ fees in the action or upon appeal.”[111]

Lien claimant must receive notice at least ten days prior to application for bond.[112]

May recover attorney’s fees.[113]

Yes[114]

Mississippi

No

None

None

None

None

No[115]

Missouri

No

None

None

None

None

Yes[116]

Montana

Yes

Contracting owner of any interest in the property may bond over a lien prior to filing of lien foreclosure action or within 30 days of notification of foreclosure action.[117]

 

Lien claimant must take action on the bond within two years of filing the lien.[118]

150% of the claim amount.[119]

None

Must be approved by court.[120]

 

May recover attorney’s fees.[121]

Yes[122]

Nebraska

Yes

Lien claimant must take action on bond no later than two years after the lien’s recording.[123]

115% of the claim amount.[124]

None

Bonding party must file certificate with clerk of the district court verifying bond deposit.[125]

No[126]

Nevada

Yes

Lien claimant must bring action on the bond within nine months of when the lien claimant was notified that the surety bond was recorded.[127]

150% of the claim amount.[128]

Notice requirements will vary depending on when the bond is filed.[129]

None

Yes[130]

New Hampshire

Yes

Lien claimant must take action on bond no later than 120 days after work was last performed.[131]

Claim amount, plus interest and costs.[132]

Must provide reasonable notice to lien claimant.[133]

None

No

New Jersey

Yes

Lien claimant must begin an action against the bond within one year of when the claimant first performed its work or within 30 days following written notice sent by certified mail or personal service from the owner that requires the claimant to commence an action to establish the lien claim.[134]

110% of claim amount, plus $25.[135]

None

None

Yes[136]

New Mexico

Yes

Lien claimant must take action on bond no later than two years after lien claim is filed.[137]

Determined by the court, but the amount must be sufficient to cover damages, court costs, and attorney’s fees.[138]

None

May recover attorney’s fees.[139]

 

Must be approved by the court.[140]

No

New York

Yes

Lien claimant must make claim on bond within eight months of final performance[141] and take action within one year of filing claim on bond.[142]

An amount directed by the court, but not less than the amount unpaid.[143]

None

Must be approved by the court.[144]

Yes[145]

North Carolina

Yes

Lien claimant must take action on bond within 180 days after last furnishing of labor or materials.[146]

125% of claim amount.[147]

None

May recover attorney’s fees.[148]

Yes[149]

North Dakota

Yes

Lien claimant has 7 days in which to file an exception to the sufficiency of the sureties with the clerk.[150]

 

Lien claimant must take action on bond within 30 days upon written demand of the owner or within three years after the lien’s recording.[151]

 

Claim amount, plus all costs.[152] 

 

Lien claimant (or its agent or attorney) must receive notice personally or by registered mail.[153]

Must be brought with two sureties.[154]

No

Ohio

Yes

Lien claimant must take action on the bond within six years of the lien’s filing.[155]

If the claim is $5,000 or less, the value of the bond must be 200% of claim amount.  For claims exceeding $5,000, the bond amount must be 150% of claim amount.[156]

Upon application to the court of common pleas for the approval of the bond, notice of a hearing regarding that application must be given to the lienholder or its agent.[157]

May recover attorney’s fees.[158]

 

Filing the bond requires court approval.[159]

No

Oklahoma

Yes

Lien claimant must provide objection to county clerk within 10 days of being notified of the bond.[160] 

 

The lien claimant must take action on the bond within 10 years of receiving notification.[161]

125% of the claim amount.[162]

County clerk must notify the lien claimant of the bond within three days of posting.[163]

 

Attorney’s fees may be recovered.[164]

No

Oregon

Yes

Lien claimant must take action on bond within 120 days after lien’s filing.[165]

 

A bond may be filed at any time after the filing of the claim of lien.[166]

150% of the claim amount or $1,000, whichever is greater.[167]

Must provide notice of the filing of the bond and a copy thereof to the lien claimant within 20 days after bond filing.[168]

May recover attorney’s fees.[169]

No

Pennsylvania

Yes

If the contractor has posted a bond guaranteeing payment for labor and materials provided by subcontractors, then the right to file a lien in the first place may be waived.[170]

Bond or Other Security Deposit:  Sum equal to 200% the amount of the required cash deposit, or such lesser amount approved by the Court, must be deposited.[171] 

 

Cash Deposit:  Sum equal to the amount of the claim must be deposited.[172]

After notice and hearing, a court may order that the amount of the cash or other security deposited be increased or decreased, allow security to be substituted, and/or take other actions.[173]

None

Yes.[174]

Rhode Island

Yes

Bond may be filed only after lien claim is filed.[175]

Where no lien foreclosure suit has been commenced at the time of the bond’s filing, the lien claimant must take action on the bond within 40 days of the lien’s filing.[176]

Where a lien foreclosure suit is pending, the lien claimant has 60 days to amend their suit and include the surety as a defendant.[177]

Claim amount, plus costs, interest, and attorney’s fees.[178]

None

May recover attorney’s fees.[179]

Yes[180]

South Carolina

Yes

Lien claimant must take action on bond within six months of last work performed.[181]

133% of the claim amount.[182]

None

May recover attorney’s fees, to be determined by the court.[183]

Yes[184]

South Dakota

Yes

Lien claimant must take action on bond within one year of lien’s discharge.[185]

200% of the claim amount, to cover interest and costs.  Must be executed by at least two sureties.[186]

Must serve notice to lien claimant at least 10 days prior to bond application.[187]

None

No[188]

Tennessee

Yes

Lien claimant must take action on bond within one year after abandonment or completion of work.[189]

Claim amount[190]

None

None

Yes[191]

Texas

Yes

Lien claimant must take action on bond within one year of notice of bond or after the date on which the underlying lien claim becomes unenforceable.[192]

200% of the claim amount for claims totaling $40,000 or less. 

 

If the claim is for more than $40,000, then the bond must equal 150% of the claim amount.[193]

County clerk must provide notice to lien claimant after the bond’s filing.[194]

May recover attorney’s fees.[195]

No

Utah

Yes

If suit is pending at time of bond filing, lien claimant must take action on bond within 90 days of receiving notice.[196]

 

If suit is not pending at time of bond filing, the lien claimant shall have six months after receiving notice to take action on the bond, except that no action may be commenced after two years from the date the notice was recorded.[197]

150% of the claim amount for claims of $25,000 or more.  175% of the claim for claims of at least $15,000 but less than $25,000.  200% of the claim amount for claims of less than $15,000.[198]

Must provide notice to lien claimant no later than 30 days after the bond’s filing.[199]

May recover attorney’s fees.[200]

Yes.[201]

Vermont

Yes

Lien claimant must take action on bond within 180 days of lien’s filing.[202]

Amount to be determined by judge.[203]

None

Must be approved by court.[204]

Yes[205]

Virginia

Yes.

The bond may be filed either before or after a suit is brought to enforce the lien.[206]

If a bond is deposited, then the amount is 200% the amount of the lien plus the costs of the suit.[207]  If cash is deposited, then the amount must equal a sum sufficient to discharge the lien plus the costs of suit.[208]

After five days notice to the lienor, the general contractor or other party in interest may apply for permission to pay into the court a sufficient amount of money or to file a bond.[209]

None

No.[210]

Washington

Yes

Bond may be filed either before or after the commencement of an action to enforce a lien in the county where the lien was recorded.[211]

 

Action to recover on the bond must be taken within eight months of when the lien is recorded, or the bond will be discharged.[212]

If the lien is $10,000 or less:  The bond must be in an amount equal to the greater of $5,000 or two times the amount of the lien claimed.[213]

 

If the lien is greater than $10,000:  The bond must be in an amount equal to or greater than 150% the amount of the lien.[214]

None

The surety providing the bond must be listed in the latest federal department of the treasury list of surety companies acceptable on federal bonds.[215]

No.

West Virginia

Yes

Owner must record the contract and the bond in the office of the county commissioner’s clerk in the county where the project is located prior to the start of construction.[216]

The amount of the contract price.[217]

None

None

No.[218]

Wisconsin

Yes

The timing proceeds as though no bond had been filed.[219]  If no action to foreclose the lien is brought within two years of filing a claim for lien, the clerk will return the bond to the party filing or depositing it.[220]

125% of the claim amount.[221]

Either the person against whom the lien is claimed or the person depositing the bond must service notice of the filing of the bond that states where and when the security was deposited.[222]

None

No.[223]

Wyoming

Yes

Bond may be filed at any time prior to a final judgment in an action to foreclose the lien.[224]  A lien claimant whose lien is satisfied by the filing of the bond must bring an action upon the bond within 180 days of when the lien statement was initially filed.[225]

150% of the lien claim.[226]

Upon the filing of the bond, the court clerk of the district court in the county where the lien was filed will issue a notice of satisfaction of lien that may be filed to show that the lien was satisfied.

Felony criminal liability may attach if a general contractor provides an affidavit to the owner stating that all subcontractors and suppliers have been paid knowing that they have not been paid.[227]

Yes.[228]

 



[1] Ala. Code § 35-11-233(b)(2).

[2] Id. §§ 35-11-233(e) and 35-11-221.

[3] Id. § 35-11-233(b)(2).

[4] Id. § 35-11-233(c).

[5] Noland Co. v. Southern Dev. Co., Inc., 445 So. 2d 266, 270 (Ala. 1984).

[6] Alaska Stat. § 34.35.080(a).

[7] Id. § 34.35.072.

[8] Id. § 34.35.117(a).

[9] Id.

[10] Id. §§ 34.35.117(b) and 34.35.120(10).

[11] Ariz. Rev. Stat. Ann. § 33-1004(D)(1).

[12] Id. § 33-1004(D)(2).

[13] Id. § 33-1004(B).

[14] Id. § 33-1004(C).

[15] Id. § 33-998(B).

[16] Id. § 33-1008(A).

[17] Ark. Code. Ann. § 18-44-118(B).

[18] Id. §§ 18-44-118(c)(1) and 18-44-119.

[19] Id. § 18-44-118(a)(1).

[20] Id. § 18-44-118(b)(1).

[21] Id. § 18-44-128.

[22] Cal. Civ. Code § 3144.5.

[23] Id.

[24] Id.

[25] Michael J. Jurkovich and Amanda Glenn Hebesha, California Construction and Design Law, in Aba Guide 95, 120.

[26] Cal. Civ. Code § 3262(b) (specifying the conditions under which lien waiver and releases may be made and the waivers and releases that must be signed, all of which relate to waiving or releasing lien rights on activities to date); see also Michael J. Jurkovich and Amanda Glenn Hebesha, California Construction and Design Law, in Aba Guide 95, 119.

[27] Colo. Rev. Stat. §§ 38-22-133; 38-22-110.

[28] Id. § 38-22-131(2).

[29] Id.

[30] Id. § 38-22-119.

[31] Conn. Gen. Stat. § 49-37(a).

[32] Id.; but see id. § 42-158o (stating that a surety is not obligated to pay interest, costs, penalties, or attorney fees imposed unless the bond’s terms expressly reference the sections providing for such payments and state that the surety is obligated to make such payments).

[33] Id.

[34] Id.

[35] Conn. Gen. Stat. § 52-249; but see id. § 42-158o (stating that a surety is not obligated to pay interest, costs, penalties, or attorney fees imposed unless the bond’s terms expressly reference the sections providing for such payments and state that the surety is obligated to make such payments)..

[36] Id. § 52-158l.

[37] Del. Code Ann. tit. 25,2729(d).

[38] Id. § 2729(c).

[39] Id. § 2729(d).

[40] Id. § 2706(b).

[41] Id.

[42] D.C. Code § 40-303.16.

[43] Id.

[44] Id.

[45] Id.

[46] Id.

[47] Id. § 40-303.02.

[48] Fla. Stat. §§ 713.22 & 713.24 (4).

[49] Id. § 713.24.

[50] Id. § 713.24(1)(b).

[51] Id.

[52] Id. § 713.20.

[53] Ga. Code Ann. § 44-14-364(a).

[54] Id.

[55] Id.

[56] Id. § 44-14-366.

[57] Haw. Rev. Stat. § 507-43(e).

[58] Id. § 507-45.

[59] Id. § 507-47.

[60] Tred R. Eyerly et al, Hawaii Construction and Design Law, in Aba Guide 275, 286 (stating that no custom exists for the use of “no lien” contracts and that scrutinization of Hawaii’s common law would be necessary to determine enforceability).

[61] Idaho Code Ann. § 45-510.

[62] Id. § 45-519.

[63] Id. § 45-520(3).

[64] Id. § 45-519.

[65] Id.

[66] Though there is not an anti-advance lien waiver statute, Idaho courts have declared advance lien waivers to be unenforceable unless supported by consideration.  James L. Martin and Tyler J. Anderson, Idaho Construction and Design Law, in Aba Guide 291, 305.

[67] 770 Ill. Comp. Stat. 60/1(d).

[68] Ind. Code § 32-28-3-11.

[69] Id. § 32-28-3-6.

[70] Id. § 32-28-3-11

[71] Id.

[72] Id.

[73] Id. § 32-28-3-16.

[74] Iowa Code § 572.27.

[75] Id. § 572.15.

[76] Id.

[77] Id. § 572.13.

[78] Kan. Stat. Ann. § 60-1105.

[79] Id. § 60-1110.

[80] Id.

[81] Id. § 16-1803.

[82] Ky. Rev. Stat. Ann. § 376-100.

[83] Id. § 376-090.

[84] Id. § 376-100.

[85] Id.

[86] Id. § 371.405(2)(b).

[87] La. Civ. Code Add. art. 9:4823.

[88] Id. art. 9:4823(B).

[89] Id. art. 9:4835.

[90] Id.

[91] Id.

[92] Me. Rev. Stat. Ann. tit. 10, § 3263.

[93] Id.

[94] Id.

[95] Id.

[96] Md. Code Ann., Real Prop. § 9-109.

[97] Md. Rule 12-307.

[98] Id.

[99] Md. Code Ann., Real Prop. § 9-113 (applying to executory contracts between contractors and subcontractors that are related to construction, alteration, or repair of a building, structure, or improvement).

[100] Mass. Gen. Laws ch. 254, § 14.

[101] Id.

[102] Id.

[103] Id.

[104] Advance lien waivers may or may not be allowed under Massachusetts law depending upon the party being asked to make the waiver.  See, e.g., Todd L. Tisdale, Ann M. Sobolewski, and Wendy K. Thomas, Massachusetts Construction and Design Law, in Aba Guide 493,510.

[105] Mich. Comp. Laws § 570.1116(2).

[106] Id. § 570.1116(1).

[107] Id.

[108] Id. § 570.1115(1).

[109] Minn. Stat. § 514.10.

[110] Id. § 514.221(3)(a).

[111] Id. § 514.10.

[112] Id.

[113] Id.

[114] Id. § 337.10.

[115] Rod Clement and Bo Harwell, Mississippi Construction and Design Law, in Aba Guide 581, 591 (stating that contracts with advance waivers are not common practice and probably would not be enforceable).

[116] Mo. Rev. Stat. § 429.005.

[117] Mont. Code Ann. § 71-3-551(1).

[118] Id. §§ 71-3-553 and 71-3-562.

[119] Id. § 71-3-551(2).

[120] Id.

[121] Id. § 71-3-551(3).

[122] Id. § 28-2-723.

[123] Neb. Rev. Stat. § 52-140(1).

[124] Id.§ 52-142(a).

[125] Id. § 52-142(b).

[126] Id. § 52-144 (stating that a written lien waiver signed by the claimant does not require consideration and is effective even if issued before the contracting or furnishing of materials and/or services).

[127] Nev. Rev. Stat. § 108.2421(2)(b)(1).

[128] Id. § 108.2415(1).

[129] Id. § 108.2415(4).

[130] Id. § 108.2453(2)(a).

[131] N.H. Rev. Stat. § 447:9.

[132] Id. § 511:49.

[133] Id. § 511:48.

[134] N.J. Stat. Ann. § 2A:44A-14.

[135] Id. § 2A:44A-31.

[137] N.M. Stat. § 48-2-10.

[138] Id. § 48-2-9(B).

[139] Id.

[140] Id.

[141] N.Y. Lien Law § 10(1).

[142] Id. § 17.

[143] Id. § 37(1).

[144] Id. § 37(4).

[145] Id. § 34.

[146] N.C. Gen. Stat. § 44A-13(a).

[147] Id. § 44A-16.

[148] Id. § 44A-35.

[149] Id. § 44A-12(f).

[150] N.D. Cent. Code § 35-21-04.

[151] Id.§ 35-27-25.

[152] Id. § 35-21-02(3).

[153] Id. § 35-21-03.

[154] Id.

[155] Ohio Rev. Code Ann. § 1311.13(C).

[156] Id. § 1311.11(C)(1).

[157] Id. § 1311.11(C)(1).

[158] Id. § 1311.16.

[159] Id. § 1311.11(C).

[160] Okla. Stat. tit. 42, § 147.1.

[161] Id.

[162] Id.

[163] Id.

[164] Id.

[165] Or. Rev. Stat. §§ 87.055 & 87.083.

[166] Id. § 87.076(3).

[167] Id. § 87.076(1).

[168] Id. § 87.078(1).

[169] Id. § 87.076(1).

[170] 49 Pa. Stat. Ann. § 1401.

[171] Id. § 1510(d).

[172] Id. § 1510(a).

[173] Id. § 1510(e).

[174] Id. § 1401.  Waivers are still permitted in some situations under the statute, though.  Id.

[175] R.I. Gen. Laws § 34-28-17(a).

[176] Id. §§ 34-38-10(a) & 34-28-17(b)(1).

[177] Id. § 34-28-17(b)(2).

[178] Id. § 34-28-17(a).

[179] Id.

[180] Id. § 34-28-1(b).

[181] S.C. Code Ann. §§ 29-5-110 & 29-5-120.

[182] Id. § 29-5-110

[183] Id. § 29-5-10.

[184] Id. § 29-7-20(2).

[185] S.D. Codified Laws § 44-4-8.

[186] Id. § 44-4-3.

[187] Id. § 44-4-5.

[188] Id. § 44-9A-1.

[189] Tenn. Code Ann. § 66-11-106.

[190] Id. § 66-11-142(a).

[191] Id. § 66-11-124(b).

[192] Tex. Prop. Code Ann. §§ 53.175 and 53.158 .

[193] Id. § 53.175(a).

[194] Id. § 53.173.

[195] Id. §§ 53.156 and 53.172.

[196] Utah Code Ann. § 38-1-28(2)(v)(4)(b).

[197] Id. § 38-1-28(5)(ii)(6).

[198] Id. § 38-1-28(2)(ii)(A-C).

[199] Id. § 38-1-28(2)(v)(4)(a).

[200] Id. § 38-1-28(2)(iv)(B).

[201] Id. § 38-1-29.

[202] Vt. Stat. Ann. tit. 9, § 1924.

[203] Vermont Rules of Civil Procedure, Rule 4.1(e)(2).

[204] Vermont Rules of Civil Procedure, Rule 4.1(e)(2).

[205] Vt. Stat. Ann. tit. 9, § 1921(f).

[206] Va. Code Ann. §§ 43-70 & 43-71.

[207] Id. §§ 43-70 & 43-71.

[208] Id.

[209] Id.

[210] Id. § 43-3(C); see also Neil S. Kessler & Lile T. Trice, Virginia Construction and Design Law, in ABA Guide 1051, 1060 (stating that consideration was required for a lien waiver to be valid).

[211] Wash. Rev. Code. § 60.04.161.

[212] Id. §§ 60.04.161 & 60.04.141.

[213] Id. § 60.04.161.

[214] Id. § 60.04.161.

[215] Id. § 60.04.161.

[216] W. Va. Code. §§ 38-2-22 & -23.

[217] Id.

[218] James R. Snyder & Ellen S. Cappellanti, West Virginia Construction and Design Law, in ABA Guide 1091, 1104 (citing Bauer Enters., Inc. v. Frye, 382 S.E.2d 71 (W. Va. 1989) (recognizing the possibility of waiver)).

[219] Wis. Stat. § 779.08(4).

[220] Id. §§ 779.08(5) & 779.06(1).

[221] Id. § 779.08(1) & (2).

[222] Id. § 779.08(3).

[223] Id. § 779.05.

[224] Wyo. Stat. Ann. § 29-1-310(c).

[225] Id. § 29-2-109.

[226] Id. § 29-1-310.

[227] Id. § 6-3-608.

[228] Id. § 29-2-106.