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List of Forms by Chapter - Chapter 1— Introduction to the Illinois Mechanics Lien Statute
- I. [1.1] Introduction
- II. [1.2] Mechanics Lien Statute and Common Law
- III. [1.3] Purpose of the Mechanics Lien Act
- IV. [1.4] Who Is Entitled to Assert a Mechanics Lien?
-
V. [1.5] Types of Mechanics Liens - VI. Principals of the Mechanics Lien Act
- [1.9] Mechanics Lien Act Is Part of Every Contract
- [1.10] There Must Be a Contract To Improve Real Estate
- [1.11] Contract Must Be with the Owner or One Knowingly Permitted by the Owner
- Ownership Interests
- [1.12] Joint Owners
- [1.13] Vendee
- [1.14] Tenant
- [1.15] Equitable Ownership
- [1.16] Knowingly Permitted
- [1.17] Mechanics Lien Is Cumulative and Additional Remedy
- [1.18] Relation-Back Doctrine
- VII. [1.19] Perfecting the Mechanics Lien
- VIII. [1.23] Contractors’ Sworn Statements and Subcontractors’ Affidavits
- IX. [1.24] Benefits Conveyed Under the Mechanics Lien Act
- [1.25] Security Interests and Apportionment
- [1.26] Interest Earned on Lien Claims Until Payment
- [1.27] Subcontractor Granted Remedy Against Owner Without Privity of Contract
- [1.28] Owners’ Liability Is Limited
- [1.29] Owners Can Accelerate Statute of Limitations To Adjudicate Lien Claims
- [1.30] Third Parties’ Liability Is Limited
- X. [1.31] Waivers of Lien
- XI. [1.34] Enhancement Doctrine
- XII. [1.35] There Must Be Strict Compliance with Technical Requirements
- [1.36] Reasons for Rule of Strict Compliance
- [1.37] Mechanics Lien Is in Derogation of Common Law
- [1.38] Mechanics Lien Is Extraordinary Remedy
- Steps for Technical Compliance
- [1.39] 770 ILCS 60/5 and 60/21 — 60-Day Notice
- [1.40] 770 ILCS 60/24 — 90-Day Notice
- [1.41] 770 ILCS 60/7 — Four-Month Recording and Lien Content
- [1.42] 770 ILCS 60/7 — Two-Year Filing
- [1.43] Third Parties and Strict Construction
- [1.44] Reasonability Factor with Application of Rule of Strict Construction
- XIII. [1.45] Mechanics Lien Act Is Liberally Construed as Remedy
- XIV. [1.46] Multiple Parcels of Property
- XV. [1.49] Substitution of Bond
- Chapter 2 — Requirements for the Original Contractor’s Lien on Private Projects
- I. Overview
- II. Identifying Contractors and Persons Authorized or Knowingly Permitted by Owners
- III. Identifying Lienable Work
- [2.10] Lienable Work
- [2.11] Environmental Services
- [2.12] Surveying Services
- [2.13] Pre-Construction Services by Contractors or Construction Managers
- [2.14] Lienability of “Delay Damages”
- [2.15] Drawings for an Abandoned Project
- [2.16] Materials, Fixtures, and Machinery
- [2.17] Streets
- [2.18] Equipment
- [2.19] Equipment Rental
- [2.20] Construction Managers and Property Managers
- [2.21] “Ornamenting” Property
- [2.22] Cleaning and Moving
- [2.23] Union Wages and Union Fringe Benefits
- [2.24] Trucking Services
- [2.25] Fee, Profit, and Overhead
- [2.26] Temporary Staffing Labor — Not Lienable
- [2.27] Interior Designers
- [2.28] Combining Lienable and Non-Lienable Work
- [2.29] Other Categories of Lienable and Non-Lienable Items
- [2.30] Interest on Unpaid Amounts, Costs of Collection, and Attorneys’ Fees
- IV. Contract Provisions and Lien Rights
- [2.31] No-Lien Contracts
- [2.32] Subordination Agreements
- [2.33] Waivers of Lien
- [2.34] Three-Year/Five-Year Rule and Contract Completion
- [2.35] Failure To Satisfy All Contract Conditions
- Legality of Contract
- [2.36] Home Repair and Remodeling Act
- [2.37] Licensing Requirements
- [2.38] Permit Requirements
- [2.39] Section 5 Sworn Statements — Contractor’s Affidavit
- V. The Claim for Lien — Timing and Contents
- Timing Requirements To Preserve Lien Rights
- [2.40] Four-Month/Two-Year Rules
- [2.41] “Completion” of the Work
- [2.42] Incorrect Completion Date
- [2.43] Allocation and Apportionment Issues
- [2.44] Overstated Liens
- [2.45] Thirty-Day Rule — Section 34
- [2.46] Information Needed To Prepare the Claim for Lien
- [2.47] Preparing the Claim for Lien
- [2.48] Sample Claim for Lien
- [2.49] Commentary on Sample Claim for Lien
- [2.50] Amended Lien Claims
- [2.51] Priority of the Perfected Lien Claim
- [2.52] Mortgage Lenders, Time of Recording and Contract Date, and the Enhancement Doctrine
- [2.53] Priority Among Mechanics Lien Claimants
- [2.54] Priority of Receiver’s Certificates
- VI. Section 38.1 Lien Substitution Bonds
- Chapter 3 — Subcontractor’s Claim for Lien
- I. [3.1] Nature and Enforcement: The Subcontractor’s Lien Rights
- [3.2] Nature of a Subcontractor’s Lien
- [3.3] “Subcontractor” Defined
- [3.4] Who Is an Owner
- [3.5] Contracts with One Other than the Record Title Owner
- [3.6] Contracts with One Who Is Knowingly Permitted
- [3.7] Contract Terms Restricting Lien Rights
- [3.8] Perfecting a Subcontractor’s Lien Claim
- [3.9] A Subcontractor’s Right to Relief
- II. [3.10] Four Prerequisites to Subcontractor’s Lien
- III. Preserving Subcontractor’s Lien
- 90-Day Notice
- [3.11] Serving 90-Day Notice
- [3.12] Form of 90-Day Notice
- [3.13] Parties To Be Served with 90-Day Notice
- Method of Service of 90-Day Notice
- [3.14] In General
- [3.15] Joint Ownership
- Exception to Service of 90-Day Notice
- [3.16] When the Sworn Contractor Statement Is Correct
- [3.17] When the Sworn Contractor Statement Is Incorrect
- [3.18] When No Sworn Statement Is Obtained by Owner
- 60-Day Notice
- [3.19] Serving 60-Day Notice
- [3.20] Form of 60-Day Notice
- [3.21] Notice to Persons Not Found in County or Not Residing Therein
- [3.22] Time of Service of Notice
- [3.23] Recording the Subcontractor’s Claim for Lien — Time for Filing
- IV. Subcontractor Remedies
- Chapter 4 — Sub-Subcontractor’s Lien: Requisites for and Perfection Of
- Chapter 5 — Mechanics Liens on Funds for City, County, and State Projects
- I. [5.1] Introduction
- II. [5.2] Prerequisites to a Public Works Lien
- III. Perfection of the Lien
- IV. The Lawsuit
- V. Litigation Considerations
- [5.15] Multiple Claimants — Insufficient Recovery
- [5.16] Asserting the General Contractor’s Extras To Increase the Pot of Available Money
- [5.17] Addressing the Owner’s Back Charges Against the General Contractor
- [5.18] Interest
- [5.19] Depositing Funds with the Clerk
- [5.20] Limitation on Amount Recoverable
- VI. [5.21] If the Public Body Fails To Withhold Payment as Required: Claim Against the Public Official’s Bond
- Chapter 6 — Construction Bond Claims
- I. Recovery on Bonds for State and Local Jobs
- Background
- [6.1] Purpose of the Public Construction Bond Act
- [6.2] Separate Remedy
- [6.3] Terms of the Bond
- To Whom the Public Construction Bond Act Applies
- [6.4] State or Political Subdivision
- [6.5] Who Provides the Bond
- [6.6] Who Can Recover
- What Claims Can Be Recovered
- [6.7] Types of Recoverable Expenses
- [6.8] Bond Can Exceed Statutory Requirements
- [6.9] Amount of Recovery
- [6.10] Subcontractor Working on Multiple Jobs
- [6.11] When Subcontractor Executes Waiver of Lien
- [6.12] Instances When Surety Is Released from Liability
- Procedural Considerations in Bringing Suit on the Bond
- [6.13] Notice Requirements
- [6.14] When Suit May Be Brought
- [6.15] Where Suit Can Be Brought
- [6.16] The Complaint and Copy of the Bond
- [6.17] Sample Public Construction Bond Act Notice
- II. [6.18] Recovery on Bonds for Private Jobs
- III. Recovery on Bonds for Federal Jobs
- [6.21] The Statute
- [6.22] Obtaining a Copy of the Bond
- [6.23] Accrual of Action on the Bond
- [6.24] Procedural Steps for Recovery on the Bond
- [6.25] Who May Recover
- What Claims Can Be Recovered
- [6.26] Claims for Materials Intended To Be Used
- [6.27] Subcontractors Working on Multiple Jobs
- [6.28] Rentals, Repairs, and Replacement Parts
- [6.29] Interest and Attorneys’ Fees
- Forms
- [6.30] Affidavit To Support Request for Certified Copy of Miller Act Bond
- [6.31] Transmittal Letter To Obtain Certified Copy of Miller Act Bond
- [6.32] Sample Miller Act Notice
- Chapter 7 — Mechanics Liens in Bankruptcy
- I. [7.1] Introduction
- II. Brief Overview of Bankruptcy
- III. [7.5] The Automatic Stay
- [7.6] Recording the Mechanics Lien — An Exception to the Automatic Stay
- [7.7] Perfecting the Mechanics Lien
- [7.8] Notice Requirements To Perfect Liens Against Owner-Occupied, Single-Family Residence
- [7.9] Tolling and Necessary Party
- [7.10] 770 ILCS 60/34 Demand and the Automatic Stay
- [7.11] Modification of the Automatic Stay
- [7.12] To Modify or Annul
- [7.13] Procedure for Filing the Motion
- [7.14] Required Statement To Accompany All Motions for Relief from Stay
- Standards for Granting the Motion
- [7.15] Necessary Party
- [7.16] Owner
- [7.17] Other Options
- IV. [7.18] Sale of Property Under 11 U.S.C. §363
- [7.19] Is It Appropriate for the Trustee To Sell the Property?
- [7.20] How Will the Sale Be Conducted?
- [7.21] What Constitutes Adequate Notice of the Proposed Sale?
- [7.22] Will the Proposed Sale Be Free and Clear of All Liens and Other Interests in the Subject Property?
- [7.23] Has the Interest of the Lienholder Been Adequately Protected?
- [7.24] Can the Lien Claimants Credit Bid an 11 U.S.C. §363 Sale?
- [7.25] How Will the Holder of a Mechanics Lien Be Made Aware of a Trustee’s Intent To Sell Property Free and Clear of Its Lien?
- V. [7.26] Motion To Abandon vs. Modify Stay — Which To Choose?
- VI. [7.27] Proofs of Claim
- VII. Preferences
- VIII. [7.32] Nondischargeability Claims by Lien Claimants
- Chapter 8 — Trial Practice: Pleading Practice
- I. Pleading Practice
- [8.1] Identifying “Necessary Parties”
- [8.2] Defects in Claim for Lien
- [8.3] Counterclaims
- [8.4] Private Lien Foreclosure Suits in Federal Court
- [8.5] Construction Trust Funds
- [8.6] Secondary Subcontractors’ Foreclosure Actions
- [8.7] Municipalities’ Actions To Recover Lienable Improvements
- [8.8] 735 ILCS 5/2-619 Motions To Dismiss
- [8.9] Attorneys’ Fees
- II. Proof of Selected Issues
- Chapter 9 — Trial Practice: Breach and Damages
- I. [9.1] Trial in General
- II. [9.2] Breach
- III. [9.3] Measure of Damages
- [9.4] Full Performance
- [9.5] Substantial Performance
- [9.6] Owner’s Claim Against General Contractor for Lien Judgment
- [9.7] Owner’s Breach/No Substantial Performance by Contractor
- [9.8] Builder’s Breach/No Substantial Performance by Contractor
- [9.9] Effect of Statutory Violations on Mechanics Lien and Contract Claims
- [9.10] Breach of Mechanics Lien Act
- [9.11] Breach of Home Repair and Remodeling Act by Contractor
- [9.12] Other Types of Damages in Construction Cases; Incidental Expenses
- [9.13] Lost Profits
- [9.14] Interest
- [9.15] Attorneys’ Fees
- IV. [9.16] Quantum Meruit and Unjust Enrichment
- Contracts Implied in Fact
- [9.17] Background
- [9.18] Appellate Review
- [9.19] Case Study: Trapani Construction Co. v. Elliot Group, Inc.
- Contracts Implied in Law
- [9.20] Unjust Enrichment
- [9.21] Quantum Meruit
- [9.22] Appellate Review
- Case Studies
- [9.23] Unjust Enrichment: C. Szabo Construction, Inc. v. Lorig Construction Co.
- [9.24] Quantum Meruit: Archon Construction v. U.S. Shelter, L.L.C.
- Chapter 10 — Statutory Defenses of Mechanics Lien Claims
- I. [10.1] Introduction
- II. Contract Requirements — Section 1 of the Mechanics Lien Act
- III. [10.10] General Contractor’s Notice Requirement — Section 5 of the Mechanics Lien Act
- IV. Timing and Contents of Mechanics Lien Claims — Section 7 of the Mechanics Lien Act
- [10.16] Section 7 of the Mechanics Lien Act
- [10.17] Mechanics Lien Timing Requirements
- [10.18] Four-Month Rule
- [10.19] Two-Year Requirement
- [10.20] Necessary Parties
- [10.21] Three-Year and Five-Year Completion Requirements
- [10.22] Mechanics Lien Contents Requirements
- [10.23] Verification of Claim for Lien
- [10.24] Brief Statement of the Contract
- [10.25] Balance Due — Mere Overstatement Found Not To Be Constructive Fraud
- [10.26] Balance Due — Overstatement with Evidence of Constructive Fraud
- [10.27] Description of the Property
- [10.28] Contractor or Subcontractor
- [10.29] Completion Date
- [10.30] Inaccurate Completion Date Stated in Mechanics Lien
- [10.31] Amendment of Mechanics Lien
- V. [10.32] Receivership and Subordination of Mechanics Liens — Section 12 of the Mechanics Lien Act
- VI. [10.33] Subcontractor’s Required Notices — Sections 21 and 24 of the Mechanics Lien Act
- [10.34] Section 21 — Subcontractor’s Required Notice (Owner Occupied, Single Family)
- [10.35] Section 24 — Subcontractor’s Required Notice
- [10.36] Certified Mailing
- [10.37] Section 24 — Service of Process Including Claim for Lien
- [10.38] Section 28 — Timing of Subcontractor’s Lien Recording or Enforcement
- VII. [10.39] Statutory Limits on Liability of Owner — Sections 21, 27, and 30 of the Mechanics Lien Act
- VIII. [10.40] 30-Day Notice To Commence Suit — Section 34 of the Mechanics Lien Act
- IX. [10.46] Bonding Over Mechanics Liens
- X. [10.47] Recorded Release of Lien — Section 35 of the Mechanics Lien Act
- XI. [10.48] Summary Conclusion — The Mechanics of a Mechanics Lien Claim
- Chapter 11 — Common-Law and Consumer Statutory Defenses
- I. [11.1] A Contract Between Owner and Contractor
- II. [11.2] Owner — A Person or Entity with Any Legal or Beneficial Title
- III. [11.3] Only the Owner’s Interest Is Subject to Lien
- IV. [11.4] Illinois Homestead Exemption
- V. [11.5] “Owner” and “Owner of Record”
- VI. [11.6] Contractor or Joint Venturer
- VII. [11.7] Improvements Authorized or Knowingly Permitted
- VIII. [11.12] Legality of Contract
- IX. [11.17] Extras; Supplemental and Additional Work
- X. [11.21] Contract Terms Influencing Lien Rights — The Hierarchy of Contract Power
- [11.22] Contract Price — A Limit of Owner Liability
- [11.23] Payment upon Architect’s Certificate — Presentation of Waivers
- [11.24] Completion Beyond Three Years from Commencement
- [11.25] Waiver of Contract Terms
- [11.26] “No-Lien” Contract Provisions
- [11.27] Pay-If-Paid Provisions
- [11.28] Settlement with Owner
- [11.29] Completion
- [11.30] Alternative Dispute Resolution
- XI. [11.31] Performance, Breach, Justifiable Abandonment
- XII. [11.39] Estoppel — Constructive Fraud
- XIII. [11.40] Slander of Title
- XIV. [11.41] Waiver of Liens
- [11.42] Is There Reliance if Owner Knows Subcontractor Is Not Paid?
- [11.43] Owner Fraud on Subcontractor
- [11.44] Trade Usage/Customary Practice
- [11.45] Ambiguous Waiver
- [11.46] Waiver of Lien on Premises or Money Due or Both?
- [11.47] Stolen Lien Waivers
- [11.48] Consideration Not Required
- [11.49] Waiver of Lien for Future Work
- [11.50] Reformation of Full Waivers to Partial Waivers
- [11.51] Mistakenly Issued Waivers
- [11.52] Owner Breach
- XV. [11.53] A Few Common Nonstatutory Claims Against Owners
- Chapter 12 — Miscellaneous Remedies
- I. [12.1] Scope of Chapter
- II. Alternative Theories of Recovery
- [12.2] Mechanics Lien Act as Exclusive Remedy Against Those Not in Privity of Contract
- [12.3] Equitable Liens
- [12.4] Third-Party Beneficiary Theory
- [12.5] Subcontractors and Owners Are Incidental Beneficiaries to Each Other
- [12.6] Conflicting Claims Among General Contractor’s Creditors
- [12.7] Actions Against Surety on Payment Bonds
- [12.8] Actions Against Government Agency for Failure To Obtain Statutory Bond
- [12.9] United States Department of Housing and Urban Development Projects
- [12.10] Unjust Enrichment/Quantum Meruit
- [12.11] Constructive Trusts
- [12.12] Sureties
- [12.13] Contractors
- [12.14] Bankruptcy
- III. [12.15] Assignment
- IV. [12.16] Copartners or Joint Claimants
- V. [12.17] Death
- VI. [12.18] Fire or Other Destruction
- VII. [12.19] Former Adjudication
- VIII. [12.20] General Settlement
- IX. [12.21] Merger
- X. [12.22] Mistake
- XI. [12.23] Novation
- XII. [12.24] Removal of Material from Site
- XIII. [12.25] Subrogation
- XIV. [12.26] Watercraft
- Chapter 13 — Attorneys’ Fees and §17 of the Mechanics Lien Act
- I. [13.1] Introduction
- II. [13.2] Section 17 of the Mechanics Lien Act
- III. [13.3] Awards of Attorneys’ Fees — Generally
- IV. [13.4] Specific Findings Under §17 of the Mechanics Lien Act
- V. [13.5] Prevailing Party Doctrine
- VI. Attorney’s Fee Awards to Contractors — Section 17(B)
- VII. [13.9] Attorney’s Fee Awards to Owners — Section 17(C)
- VIII. [13.10] Conclusion
- Chapter 14 — Forms
- I. [14.1] Mechanics Lien Information Statement — Public Project
- II. [14.2] Mechanics Lien Information Statement — Private Project
- III. [14.3] Original Contractor’s Claim for Lien — Private Project
- IV. [14.4] Notice of Claim of Subcontractor or Material Supplier (770 ILCS 60/24)
- V. [14.5] Notice of Claim of Subcontractor to Owner (770 ILCS 60/5 and 60/21)
- VI. [14.6] Subcontractor’s Notice and Claim for Lien to Persons Not Found or Not Residing in County (770 ILCS 60/25)
- VII. [14.7] Subcontractor’s Claim for Lien
- VIII. [14.8] Contractor’s Affidavit (770 ILCS 60/5)
- IX. [14.9] Subcontractor’s Notice to Owner — Owner-Occupied, Single-Family Residence (770 ILCS 60/5)
- X. [14.10] Notice and Demand To Commence Suit — Private Project (770 ILCS 60/34)
- XI. [14.11] Final Waiver of Lien — Unlimited as to Time
- XII. [14.12] Partial Waiver of Lien — Limited to Amount Paid
- XIII. [14.13] Waiver of Lien to Date — Unlimited as to Amount
- XIV. [14.14] Affidavit as to Unknown Owners, Unknown Necessary Parties, and Non-Record Claimants (770 ILCS 60/11)
- XV. [14.15] Affidavit for Publication
- XVI. [14.16] Notice of Foreclosure — Lis Pendens
- XVII. [14.17] General Contractor’s Complaint To Foreclose Mechanics Lien
- XVIII. [14.18] Judgment of Foreclosure and Sale
- XIX. [14.19] Public Lien and Bond Claim Notice
- XX. [14.20] Release of Mechanics Lien Claim — Private Project
- XXI. [14.21] Release of Public Funds Lien, Bond Claim, and Contract Claims — Public Project
- Eric A. Berg
Eric A. Berg
Eric A. Berg is Of Counsel to Ogletree, Deakins, Nash, Smoak & Stewart, P.C., in Chicago, where he focuses on construction transactions and litigation. He has been rated AV Preeminent (5 out of 5) by Martindale-Hubbell and is a member of the Society of Illinois Construction Attorneys and the American Bar Association Forum on Construction Law. Mr. Berg received his B.A. from Yale University and his J.D. from the Northwestern University Pritzker School of Law.
- W. Matthew Bryant
W. Matthew Bryant
W. Matthew Bryantis Counsel to Saul Ewing LLP in Chicago, where he focuses on construction law. He is a member of the Trial Bar of the United States District Court for the Northern District of Illinois, the Steering Committee of the American Bar Association Forum on Construction Law Division 7, and the Society of Illinois Construction Lawyers. Mr. Bryant received his B.A. from the University of Chicago and his J.D. from the Loyola University Chicago School of Law.
- Lori Chen
Lori Chen
Lori Chen is an associate at Ogletree, Deakins, Nash, Smoak & Stewart, P.C., in Chicago, where she focuses on construction. She is a member of the American Bar Association Forum on Construction Law and the National Association of Women Lawyers. Ms. Chen received her B.Arch. from the University of Southern California and her J.D. from the Indiana University Maurer School of Law.
- Brandon R. Clark
Brandon R. Clark
Brandon R. Clark is an associate at Saul Ewing LLP in Chicago, where he focuses on complex litigation and ADR proceedings involving disputes arising from commercial construction projects. He is a member of the Chicagoland Associated General Contractors’ Government Relations Committee and the American Bar Association Forum on Construction Law. Prior to entering the law, he was a licensed mechanical engineer. Mr. Clark received his B.S. in mechanical engineering from the University of Wisconsin-Madison and his J.D. cum laude from the DePaul University College of Law.
- Timothy R. Conway
Timothy R. Conway
Timothy R. Conway is Of Counsel to Conway & Mrowiec Attorneys LLLP in Chicago, where he focuses his practice on construction law. He is a member the Society of Illinois Construction Attorneys and the American Bar Association’s Forum on Construction Law. Mr. Conway received his BA from DePaul University and his JD summa cum laude from the Northwestern University Pritzker School of Law.
- James M. Dash
James M. Dash
James M. Dash is a Founding Member/Manager at Carlson Dash, LLC, in Chicago, where he focuses on construction. He is the Managing Editor of TURNER ON ILLINOIS MECHANIC’S LIENS (3d ed.), a Past Chair of the Illinois State Bar Association’s Construction Law Section Council (2016 – 2017), and a Past Chair of the Chicago Bar Association’s Mechanic’s Lien Subcommittee (1999 – 2000). Mr. Dash received his J.D. from the University of Houston Law Center, where he was Senior Associate Editor of the Houston Law Review.
- Jennifer L. Johnson
Jennifer L. Johnson
Jennifer L. Johnson is a Partner with Zanck, Coen, Wright & Saladin, P.C., in Crystal Lake, where she focuses on real estate, general civil litigation, and construction/mechanics liens. Johnson is Past President of the McHenry County Bar Association and Recipient of the Prairie State Legal Services Pro Bono Award in 2018. She received her B.A. from Marshall University and her J.D. cum laude from Thomas M. Cooley Law School (now known as Western Michigan Law School).
- Peter M. King
Peter M. King
Peter M. King is a Partner at King Holloway LLC in Chicago, where he represents parties in real estate disputes and represents employers in labor and employment matters. He is a member of the Illinois Land Title Association and the Defense Research Institute. He also served an externship with the Special Prosecutions Bureau of the Cook County State’s Attorney’s Office in Chicago. Mr. King received his undergraduate degree from Eastern Illinois University and his J.D. from the University of Illinois Chicago Law School.
- Steven D. Mroczkowski
Steven D. Mroczkowski
Steven D. Mroczkowski is a Shareholder at Buchalter, PC, in Chicago, where he concentrates in construction law. He is a member of the Society of Illinois Construction Attorneys, member and Past Chair of the Illinois State Barn Association’s Construction Law Section Council, and a member of the Chicago Bar Association. He has been recognized by Super Lawyers as a Rising Star in Construction Litigation (2020 – 2025), Creditor Debtor Rights (2025), and Business Litigation (2025). He received his JD from the Chicago-Kent College of Law, where he was on the Dean’s List and received the Dean’s Distinguished Public Service Award.
- John S. Mrowiec
John S. Mrowiec
John S. Mrowiec is a General Partner at Conway & Mrowiec Attorneys LLLP in Chicago, where he focuses his practice on construction litigation and contracts. He has been named the Chicago Lawyer of the Year in Construction Law in 2014 and in Construction Litigation in 2019 and 2025 by Best Lawyers. Mr. Mrowiec received his BA cum laude from Northern Illinois University and his JD from DePaul University College of Law, where he served as the Lead Articles & Notes Editor for the DePaul Law Review.
- William Norman
William Norman
William Norman is a Partner at King Holloway LLC in Chicago, where he focuses on commercial and real estate litigation and insurance defense. Mr. Norman received his J.D. with a Certificate in Trial Advocacy from the Loyola University Chicago School of Law.
- Dennis J. Powers
Dennis J. Powers
Dennis J. Powers is a Partner at DLA Piper LLP (US) in Chicago, where he focuses on construction law and real estate and commercial litigation. He has been selected for inclusion in Best Lawyers in America, Construction Law, and has been designated an Illinois Super Lawyer as the result of research projects conducted jointly by Law & Politics and Chicago magazines. He is also listed in Leading Lawyers for Construction Law and is a member of the American and Chicago Bar Associations and the Construction Law Forum. Mr. Powers received his J.D. from the DePaul University College of Law.
- James T. Rohlfing
James T. Rohlfing
James T. Rohlfing is a Partner at Saul Ewing LLP in Chicago, where he focuses on construction law and commercial litigation. He is an Editor and author for the ILLINOIS CONSTRUCTION LAW MANUAL (Thomson Reuters), Special Counsel and a Past President of the Illinois Mechanical & Specialty Contractors Association, and a member of the Society of Illinois Construction Attorneys. Mr. Rohlfing received his B.S. from Marquette University Business School and his J.D. from the DePaul University College of Law.
- Carolina Y. Sales
Carolina Y. Sales
Carolina Y. Sales is a Partner at Robbins DiMonte in Park Ridge, where she focuses on commercial litigation and bankruptcy. She is an Honoree for Crain’s Chicago Business 2024 Notable Women of Law and a member of the Chicago Bar Association Judicial Evaluation Committee in 2017 – 2025. She was named an Emerging Lawyer in 2018 – 2025 and a Leading Lawyer in 2021 – 2025. Ms. Sales received an Honors BA cum laude from Marquette University and her LLM with honors and her JD cum laude from the University of Illinois Chicago School of Law.
- Michael J. Torchalski
Michael J. Torchalski
Michael J. Torchalski is the owner of Torch Legal in Cary, where he focuses on civil litigation, including mechanics lien; real estate tax appeal; estate planning, probate, and trust administration; real estate transactions, and title insurance. He served a judicial internship with Judge Thomas R. McMillen of the United States District Court. He is a licensed title insurance agent and a member of the Heartland Realtor Organization’s Governmental Affairs Committee. Mr. Torchalski received his B.A. from the University of Illinois at Urbana-Champaign and his J.D. with honors from the Chicago-Kent College of Law, where he was a member of the Bar and Gavel Society.
Mechanics Liens 2023 Edition
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