Arkansas Code Annotated

Ark. Code Ann. § 18-44-115 (2026)

Notice to owner by contractor — Definitions

✓ current as of May 2026

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1. No lien upon residential real estate containing four (4) or fewer units may be acquired by virtue of this subchapter unless the owner of the residential real estate, the owner's authorized agent, or the owner's registered agent has received, by personal delivery or by certified mail, a copy of the notice set out in this subsection.
2. The notice required by this subsection shall not require the signature of the owner of the residential real estate, the owner's authorized agent, or the owner's registered agent in an instance when the notice is delivered by certified mail.
3. It shall be the duty of the residential contractor to give the owner, the owner's authorized agent, or the owner's registered agent the notice set out in this subsection on behalf of all potential lien claimants before the commencement of work.
4. If a residential contractor fails to give the notice required under this subsection, then the residential contractor is barred from bringing an action either at law or in equity, including without limitation quantum meruit, to enforce any provision of a residential contract.
5. 1. Any potential lien claimant may also give notice.
  2. 1. If before commencing work or supplying goods a subcontractor, material supplier, laborer, or other lien claimant gives notice under this section, the notice shall be effective for all subcontractors, material suppliers, laborers, and other lien claimants not withstanding that the notice was given after the project commences as defined under § 18-44-110(a)(2).
    2. If the notice relied upon by a lien claimant to establish a lien under this subchapter is given by another lien claimant under subdivision (a)(5)(B)(i) of this section after the project commences, the lien of the lien claimant shall secure only the labor, material, and services supplied after the effective date of the notice under subdivision (a)(5)(B)(i) of this section.
  3. However, no lien may be claimed by any subcontractor, laborer, material supplier, or other lien claimant unless the owner of the residential real estate, the owner's authorized agent, or the owner's registered agent has received at least one (1) copy of the notice, which need not have been given by the particular lien claimant.
6. A residential contractor who fails to give the notice required by this subsection is guilty of a violation pursuant to § 5-1-108 and upon pleading guilty or nolo contendere to or being found guilty of failing to give the notice required by this subsection shall be punished by a fine not exceeding one thousand dollars ($1,000).
7. The notice set forth in this subsection may be incorporated into the contract or affixed to the contract and shall be conspicuous, set out in boldface type, worded exactly as stated in all capital letters, and shall read as follows:
8. 1. If the residential contractor supplies a performance and payment bond or if the transaction is a direct sale to the property owner, the notice requirement of this subsection shall not apply, and the lien rights arising under this subchapter shall not be conditioned on the delivery and execution of the notice.
  2. A sale shall be a direct sale only if:
    1. The property owner orders materials or services from the lien claimant; and
    2. The lien claimant is not a home improvement contractor as defined by § 17-25-502(1) or a residential building contractor as defined by § 17-25-502(2).
1. 1. The General Assembly finds that owners and developers of commercial real estate are generally knowledgeable and sophisticated in construction law, are aware that unpaid laborers, subcontractors, and material suppliers are entitled to assert liens against the real estate if unpaid, and know how to protect themselves against the imposition of mechanics' and material suppliers' liens.
  2. The General Assembly further finds that consumers who construct or improve residential real estate containing four (4) or fewer units generally do not possess the same level of knowledge and awareness and need to be informed of their rights and responsibilities.
2. As used in this subsection:
  1. “Commercial real estate” means:
    1. Nonresidential real estate; and
    2. Residential real estate containing five (5) or more units; and
  2. “Service provider” means an architect, an engineer, a surveyor, an appraiser, a landscaper, an abstractor, or a title insurance agent.
3. Because supplying the notice specified in subsection (a) of this section imposes a substantial burden on laborers, subcontractors, service providers, and material suppliers, the notice requirement mandated under subsection (a) of this section as a condition precedent to the imposition of a lien by a laborer, subcontractor, service provider, or material supplier shall apply only to construction of or improvement to residential real estate containing four (4) or fewer units.
4. No subcontractor, service provider, material supplier, or laborer shall be entitled to a lien upon commercial real estate unless the subcontractor, service provider, material supplier, or laborer notifies the owner of the commercial real estate being constructed or improved, the owner's authorized agent, or the owner's registered agent in writing that the subcontractor, service provider, material supplier, or laborer is currently entitled to payment but has not been paid.
5. 1. The notice shall be sent to the owner, the owner's authorized agent, or the owner's registered agent and to the contractor before seventy-five (75) days have elapsed from the time that the labor was supplied or the materials furnished.
  2. The notice may be served by any:
    1. Officer authorized by law to serve process in civil actions;
    2. Form of mail addressed to the person to be served with a return receipt requested and delivery restricted to the addressee or the agent of the addressee; or
    3. Means that provides written, third-party verification of delivery at any place where the owner, the owner's registered agent, or the owner's authorized agent maintains an office, conducts business, or resides.
  3. When served by mail, the notice shall be complete when mailed.
  4. If delivery of the mailed notice is refused by the addressee or the item is unclaimed:
    1. The lien claimant shall immediately send the owner, the owner's authorized agent, or the owner's registered agent a copy of the notice by first class mail; and
    2. The unopened original of the item marked unclaimed or refused by the United States Postal Service shall be accepted as proof of service as of the postmarked date of the item.
6. The notice shall contain the following information:
  1. A general description of the labor, service, or materials furnished, and the amount due and unpaid;
  2. The name and address of the person furnishing the labor, service, or materials;
  3. The name of the person who contracted for purchase of the labor, service, or materials;
  4. A description of the job site sufficient for identification; and
  5. The following statement set out in boldface type and all capital letters:

“IMPORTANT NOTICE TO OWNER I UNDERSTAND THAT EACH CONTRACTOR, SUBCONTRACTOR, LABORER, SUPPLIER, ARCHITECT, ENGINEER, SURVEYOR, APPRAISER, LANDSCAPER, ABSTRACTOR, OR TITLE INSURANCE AGENT SUPPLYING LABOR, SERVICES, MATERIAL, OR FIXTURES IS ENTITLED TO A LIEN AGAINST THE PROPERTY IF NOT PAID IN FULL FOR THE LABOR, SERVICES, MATERIALS, OR FIXTURES USED TO IMPROVE, CONSTRUCT, OR INSURE OR EXAMINE TITLE TO THE PROPERTY EVEN THOUGH THE FULL CONTRACT PRICE MAY HAVE BEEN PAID TO THE CONTRACTOR. I REALIZE THAT THIS LIEN CAN BE ENFORCED BY THE SALE OF THE PROPERTY IF NECESSARY. I AM ALSO AWARE THAT PAYMENT MAY BE WITHHELD TO THE CONTRACTOR IN THE AMOUNT OF THE COST OF ANY SERVICES, FIXTURES, MATERIALS, OR LABOR NOT PAID FOR. I KNOW THAT IT IS ADVISABLE TO, AND I MAY, REQUIRE THE CONTRACTOR TO FURNISH TO ME A TRUE AND CORRECT FULL LIST OF ALL SUPPLIERS AND SERVICE PROVIDERS UNDER THE CONTRACT, AND I MAY CHECK WITH THEM TO DETERMINE IF ALL MATERIALS, LABOR, FIXTURES, AND SERVICES FURNISHED FOR THE PROPERTY HAVE BEEN PAID FOR. I MAY ALSO REQUIRE THE CONTRACTOR TO PRESENT LIEN WAIVERS BY ALL SUPPLIERS AND SERVICE PROVIDERS, STATING THAT THEY HAVE BEEN PAID IN FULL FOR SUPPLIES AND SERVICES PROVIDED UNDER THE CONTRACT, BEFORE I PAY THE CONTRACTOR IN FULL. IF A SUPPLIER OR OTHER SERVICE PROVIDER HAS NOT BEEN PAID, I MAY PAY THE SUPPLIER OR OTHER SERVICE PROVIDER AND CONTRACTOR WITH A CHECK MADE PAYABLE TO THEM JOINTLY. SIGNED: ADDRESS OF PROPERTY DATE: I HEREBY CERTIFY THAT THE SIGNATURE ABOVE IS THAT OF THE OWNER, REGISTERED AGENT OF THE OWNER, OR AUTHORIZED AGENT OF THE OWNER OF THE PROPERTY AT THE ADDRESS SET OUT ABOVE. CONTRACTOR”

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“NOTICE TO PROPERTY OWNER IF BILLS FOR LABOR, SERVICES, OR MATERIALS USED TO CONSTRUCT OR PROVIDE SERVICES FOR AN IMPROVEMENT TO REAL ESTATE ARE NOT PAID IN FULL, A CONSTRUCTION LIEN MAY BE PLACED AGAINST THE PROPERTY. THIS COULD RESULT IN THE LOSS, THROUGH FORECLOSURE PROCEEDINGS, OF ALL OR PART OF YOUR REAL ESTATE BEING IMPROVED. THIS MAY OCCUR EVEN THOUGH YOU HAVE PAID YOUR CONTRACTOR IN FULL. YOU MAY WISH TO PROTECT YOURSELF AGAINST THIS CONSEQUENCE BY PAYING THE ABOVE NAMED PROVIDER OF LABOR, SERVICES, OR MATERIALS DIRECTLY, OR MAKING YOUR CHECK PAYABLE TO THE ABOVE NAMED PROVIDER AND CONTRACTOR JOINTLY.”

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History. Acts 1979, No. 746, §§ 1-5; 1981, No. 669, § 1; 1983, No. 304, § 1; A.S.A. 1947, §§ 51-608.1 — 51-608.6; Acts 1995, No. 1298, § 7; 2005, No. 1994, § 98; 2005, No. 2287, § 3; 2009, No. 454, § 3; 2011, No. 271, § 5; 2017, No. 808, § 1.

Amendments. The 2005 amendment by No. 1994 substituted “violation and upon conviction” for “misdemeanor and” in (e)(3).

The 2005 amendment by No. 2287 redesignated former (e)(2)(B) as present (e)(2)(B)(i); in present (e)(2)(B)(i), substituted “The” for “This” and deleted “by registered mail, return receipt requested” following “contractor” and added (e)(2)(B)(ii).

The 2009 amendment rewrote the section.

The 2011 amendment substituted “suppliers” for “supplies” in (a)(5)(B)(i).

The 2017 amendment added (a)(8)(B)(ii); and made stylistic changes.

Research References

Ark. L. Notes.

Circo, Put the Arkansas Construction Lien Notice Statute Out of Its Misery, 2008 Ark. L. Notes 3.

Ark. L. Rev.

Comment, Contracting Away an Honest Day's Pay: An Examination of Conditional Payment Clauses in Construction Contracts, 58 Ark. L. Rev. 353.

Josh Rohe, Comment: A Primer on Arkansas Construction Lien Laws and a Call for Action to Better Protect Homeowners, 64 Ark. L. Rev. 433 (2011).

U. Ark. Little Rock L.J.

Tyler, Survey of Business Law, 3 U. Ark. Little Rock L.J. 149.

Survey of Arkansas Law, Business Law, 5 U. Ark. Little Rock L.J. 91.

Case Notes

Constitutionality.

This section does not unconstitutionally impair vested rights under contract, and one has to give notice after the effective date of this section in order to perfect a lien. Ellison v. Tubb, 295 Ark. 312, 749 S.W.2d 650 (1988) (decision under prior law).

Homeowners had standing to challenge the constitutionality of this section. Urrey Ceramic Tile Co. v. Mosley, 304 Ark. 711, 805 S.W.2d 54 (1991).

Subsection (f), exempting certain licensed contractors from giving notice to owners, is unconstitutional as violative of due process and equal protection. Urrey Ceramic Tile Co. v. Mosley, 304 Ark. 711, 805 S.W.2d 54 (1991).

Applicability.

Labor is not included in the required notice provisions of this section. Gipson v. Tyson Foods, Inc., 272 Ark. 485, 615 S.W.2d 363 (1981).

As the construction was performed by the general contractor, a licensed contractor, who used an unlicensed contractor, the commercial construction exception still applied and the materialmen's lien was therefore enforceable and did not fail for lack of notice. Seyller v. Pierce & Co., 306 Ark. 474, 816 S.W.2d 577 (1991) (decision under prior law).

Under the plain wording of subdivision (a)(8)(A) of this section, to the extent a homeowner had ordered materials or services directly from a contractor, those transactions constituted direct sales, and the contractor was not required to give the homeowner statutory notice as the homeowner was in direct privity of contract with the direct-sale contractor, and there were no undisclosed suppliers or laborers. Hammerhead Contr. & Dev., LLC v. Ladd, 2016 Ark. 162, 489 S.W.3d 654 (2016).

Exception.

Evidence held sufficient to find that exception to the notice requirement applied. National Lumber Co. v. Advance Dev. Corp., 293 Ark. 1, 732 S.W.2d 840 (1987).

Noncompliance.

Supplier held not entitled to lien against homeowners for the value of the materials supplied where neither the supplier nor the contractor had given the homeowners the notice required under this section. Gunter Bros. Lumber Co. v. Launius, 11 Ark. App. 191, 669 S.W.2d 205 (1984).

Where no notice was ever given to the owner of the leasehold or to its authorized agent of the work done in drilling for oil, the liens were not properly perfected. Dews v. Halliburton Indus., Inc., 288 Ark. 532, 708 S.W.2d 67 (1986).

The fact that the partnership did not follow the provisions of § 14-56-417 and city ordinances in dividing property into tracts is of no consequence and does not defeat the priority of the construction mortgages on each tract. National Lumber Co. v. Advance Dev. Corp., 293 Ark. 1, 732 S.W.2d 840 (1987).

A supplier is not entitled to an engineer's lien under § 18-44-105, where the services were not done by a licensed engineer, and where notice under this section was not given. Westside Galvanizing Servs., Inc. v. Georgia-Pacific Corp., 724 F. Supp. 644 (W.D. Ark. 1989), aff'd, 921 F.2d 735 (8th Cir. 1990).

Where property owner did not receive prescribed notice prior to the furnishing of materials, lien was not perfected although supplier filed lawsuit within 120 days of the last delivery of materials. Westside Galvanizing Services, Inc. v. Georgia-Pacific Corp., 921 F.2d 735 (8th Cir. 1990).

General contractor was not entitled to a lien because it failed to comply with statutory provisions to notify the owner of the commercial real estate before 75 days had elapsed from the time that the labor was supplied and the material furnished; the contractor's certified letter to the owner to transmit the lien was not timely and the purported notice failed to satisfy the requirements of this section. Cannon Remodeling & Painting, Inc. v. Mktg. Co., 79 Ark. App. 432, 90 S.W.3d 5 (2002).

Strict Compliance.

The notice provisions contained in the statute are to be strictly construed, thus requiring strict compliance; they cannot be satisfied by substantial compliance. Books-A-Million, Inc. v. Cockerman Constr. Co., 340 Ark. 467, 10 S.W.3d 857 (2000).

Subcontractor did not acquire a mechanic's and materialman's lien on a home because neither the subcontractor nor the contractor gave the homeowner the notice required by this section, which had to be strictly complied with, notwithstanding that the subcontractor provided the notice required by § 18-44-114(a). Bryant v. Jim Atkinson Tile, 100 Ark. App. 408, 269 S.W.3d 383 (2007).

Lien notice did not comply with this section, because strict compliance with the notice requirements of this section was required, and the description of work done simply tracked the language of the section, and in no way actually described the labor and materials provided by the claimant; the claimant merely stated that the lien notice was being provided in connection with sums owed and unpaid for labor and materials provided in connection with the properties. Ground Zero Constr., Inc. v. Creek, 2012 Ark. 243, 410 S.W.3d 579 (2012).

There is no qualifying language in this section that invalidates a mechanics' lien claim if the amount sought in a 75-day notice includes amounts for profits, which are not lienable; whether the amount stated in the notice can be proved at trial is not a requirement when determining strict compliance. The merits of whether the entire stated amount due and unpaid in the notice is lienable is an issue of proof to be decided by the trier of fact at trial, rather than through a motion to dismiss for failure to state a claim. Ahern Rentals, Inc. v. Salter Constr., Inc., 2014 Ark. App. 423, 439 S.W.3d 699 (2014).

In a lien case, a notice provided by a supplier strictly complied with this section because it expressly provided that the lien amount being sought was for rental equipment that was provided for a particular subcontractor; this was a sufficient general description of the labor, service, or materials provided. Ahern Rentals, Inc. v. Salter Constr., Inc., 2014 Ark. App. 423, 439 S.W.3d 699 (2014).

Supplier of rental equipment strictly complied with the requirements in the statute by providing an amount due and unpaid, even if the initial amount in the notice was ultimately for more than it could have proven as lienable. Ahern Rentals, Inc. v. Salter Constr., Inc., 2014 Ark. App. 423, 439 S.W.3d 699 (2014).

Subcontractor.

Subdivision (b)(1)(B) of this section protects a subcontractor from the contractor who fails to give notice. The distinction between contractors and subcontractors in subdivision (b)(1)(B) of this section is that the contractor has a legal duty to serve the notice before the work is commenced, while the subcontractor may serve the notice. Bryant v. Cadena Contr., Inc., 100 Ark. App. 377, 269 S.W.3d 378 (2007).

Timing of Notice.

“Important notice to owner” under this section must be given by either a contractor or subcontractor before the work is done in order for it to be of any practical value. Therefore, a trial court erred by finding that there was a valid mechanics' lien against real property based on the fact that a subcontractor was not paid for framing since the subcontractor had not delivered the notice personally or by certified mail until after the work was completed. Bryant v. Cadena Contr., Inc., 100 Ark. App. 377, 269 S.W.3d 378 (2007).

Cited: South Cent. Dist. of Pentecostal Church of God of Am., Inc. v. Bruce-Rogers Co., 269 Ark. 130, 599 S.W.2d 702 (1980); Duncan v. Davis & Earnest, Inc., 285 Ark. 143, 685 S.W.2d 509 (1985); Johnson v. Southern Elec., Inc., 29 Ark. App. 160, 779 S.W.2d 190 (1989); Land O'Frost, Inc. v. Pledger, 308 Ark. 208, 823 S.W.2d 887 (1992); Hall Contr. Corp. v. Entergy Servs., 309 F.3d 468 (8th Cir. 2002).

Notes of Decisions

Cited in 30 cases (9 in the last 5 years), 1988–2026 · leading case: Hammerhead Contracting & Dev., LLC v. Ladd, 2016 Ark. 162 (Ark. 2016).

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Hammerhead Contracting & Dev., LLC v. Ladd, 2016 Ark. 162 (Ark. 2016). · cites it 89× “The statute at issue, Arkansas Code Annotated section 18-44-115, requires a residential contractor to give the notice recited in the statute to the owner of the residential real estate before beginning work on the property.”

Temco Constr., LLC v. Gann, 427 S.W.3d 651 (Ark. 2013). · cites it 36× “Rather, the circuit court took the motion under advisement and later issued a written order granting the motion to dismiss on only one of the three grounds argued— that TEMCO’s “claims are statutorily barred by Ark. Code Ann. § 18-44-115 (a)(4)” for failure to strictly comply…”

Cannon Remodeling & Painting, Inc. v. Mktg. CO., 90 S.W.3d 5 (Ark. Ct. App. 2002). · cites it 59× “TMC alleged *7 in its counterclaim that it was entitled to damages, alleging that Cannon breached its contract and that Cannon negligently performed the work resulting in damage to the property.”

Urrey Ceramic Tile Co. Inc. v. Mosley, 805 S.W.2d 54 (Ark. 1991). · cites it 31× “[1] Provision (f) of § 18-44-115 exempts a licensed contractor doing industrial or commercial construction from having to give such a notice to property owners.”

Bryant v. Cadena Contracting, Inc., 269 S.W.3d 378 (Ark. Ct. App. 2007). · cites it 38× “Appellants James and Aileen Bryant appeal from the December 12, 2006 judgment of the Lonoke County Circuit Court, which found that subcontractors are exempt from the statutory notice requirement contained in Ark.Code Ann. § 18-44-115 (Supp. 2007), and ordered a foreclosure on…”

Dye v. Precision Found. Specialties & Flow Rite Drainage Solutions, Inc., 2022 Ark. App. 220 (Ark. Ct. App. 2022). · cites it 26× “The Dyes argue that (1) PFS failed to strictly comply with the statutory notice requirement in Ark. Code Ann. § 18-44-115 (Supp. 2021), which precluded a judgment in its favor; (2) the contract is usurious, which voids the contract; and (3) the jury’s viewing of the residence in…”

Ground Zero Constr., Inc. v. Walnut Creek, LLC, 410 S.W.3d 579 (Ark. 2012). · cites it 18× “On March 6, 2009, in lieu of answering the complaint, Marrs Electric filed a motion to dismiss Ground Zero’s lien claim, alleging that Ground Zero had not complied with the notice requirements of section 18-44-115 because Ground Zero failed to include a proper description of the…”

Books-A-Million, Inc. v. Arkansas Painting & Specialties Co., 10 S.W.3d 857 (Ark. 2000). · cites it 8× “Appellants contend that the trial court erred in enforcing the lien because the appellee did not comply with the statutory notice requirements under Ark. Code Ann. § 18-44-115 (Supp. 1999). We agree and reverse.”

Bryant v. Jim Atkinson Tile, 269 S.W.3d 383 (Ark. Ct. App. 2007). · cites it 64× “This case presents two questions: first, must notice be provided to the property owner under Ark. Code Ann. § 18-44-115 (Supp.2007) before a subcontractor may obtain a valid lien on the property and, second, if the answer to that question is yes, when must notice be provided? We…”

Ellison v. Tubb, 749 S.W.2d 650 (Ark. 1988). · cites it 8× “1985) and Ark.Code Ann. § 18-44-115 (1987). On April 23, 1979, after the passage of the act but before its effective date, the landowners, appellees Samuel and Debra Millican, entered into a contract with appellee Billy Tubb for construction of a home.”

Seyller v. Pierce & Co., 816 S.W.2d 577 (Ark. 1991). · cites it 10× “Specifically, appellants claim they should have received pre-construction notice of any potential liens as required by Ark. Code Ann. § 18-44-115 (1987). It is undisputed that appellants did not receive the requisite notice.”

Aaron C. Sluyter & Cheryl Sluyter v. Wood Guys, LLC, 2021 Ark. App. 442 (Ark. Ct. App. 2021). · cites it 22× “Under Ark. Code Ann. § 18-44-115 no lien may be acquired on residential real estate unless the owner or owner’s authorized agent has received the notice set forth in Ark.”

Show all 30 citing cases →

— Ark. Code Ann. § 18-44-115(1987) — 1 case

Seyller v. Pierce & Co., 816 S.W.2d 577 (Ark. 1991). “Specifically, appellants claim they should have received pre-construction notice of any potential liens as required by Ark. Code Ann. § 18-44-115 (1987). It is undisputed that appellants did not receive the requisite notice.”

— Ark. Code Ann. § 18-44-115(a) — 8 cases

Hammerhead Contracting & Dev., LLC v. Ladd, 2016 Ark. 162 (Ark. 2016). “The statute at issue, Arkansas Code Annotated section 18-44-115, requires a residential contractor to give the notice recited in the statute to the owner of the residential real estate before beginning work on the property.”

Temco Constr., LLC v. Gann, 427 S.W.3d 651 (Ark. 2013). “Rather, the circuit court took the motion under advisement and later issued a written order granting the motion to dismiss on only one of the three grounds argued— that TEMCO’s “claims are statutorily barred by Ark. Code Ann. § 18-44-115 (a)(4)” for failure to strictly comply…”

Urrey Ceramic Tile Co. Inc. v. Mosley, 805 S.W.2d 54 (Ark. 1991). “[1] Provision (f) of § 18-44-115 exempts a licensed contractor doing industrial or commercial construction from having to give such a notice to property owners.”

Ellison v. Tubb, 749 S.W.2d 650 (Ark. 1988). “1985) and Ark.Code Ann. § 18-44-115 (1987). On April 23, 1979, after the passage of the act but before its effective date, the landowners, appellees Samuel and Debra Millican, entered into a contract with appellee Billy Tubb for construction of a home.”

Aaron C. Sluyter & Cheryl Sluyter v. Wood Guys, LLC, 2021 Ark. App. 442 (Ark. Ct. App. 2021). “Under Ark. Code Ann. § 18-44-115 no lien may be acquired on residential real estate unless the owner or owner’s authorized agent has received the notice set forth in Ark.”

— Ark. Code Ann. § 18-44-115(a)(1) — 2 cases

— Ark. Code Ann. § 18-44-115(a)(3) — 2 cases

— Ark. Code Ann. § 18-44-115(a)(4) — 7 cases

Sharon Marcum v. Robert Hodge, Special Adm'r of the Est. of Nicholas Hendricks, 2023 Ark. 103 (Ark. 2023).

Sharon Marcum v. Robert Hodge, Special Adm'r of the Est. of Nicholas Hendricks, 2022 Ark. App. 497 (Ark. Ct. App. 2022).

Seaside Pools, Inc. v. Robert Lee Curtis, Jr., & Sheila Dawn Curtis, 2026 Ark. App. 245 (Ark. Ct. App. 2026).

— Ark. Code Ann. § 18-44-115(a)(7) — 5 cases

Denney v. Denney, 2015 Ark. 257 (Ark. 2015).

Ray & Elizabeth Evans v. O.A.K. Constr., Inc. (Ark. Ct. App. 2025).

Seaside Pools, Inc. v. Robert Lee Curtis, Jr., & Sheila Dawn Curtis, 2026 Ark. App. 245 (Ark. Ct. App. 2026).

— Ark. Code Ann. § 18-44-115(a)(8) — 5 cases

Sharon Marcum v. Robert Hodge, Special Adm'r of the Est. of Nicholas Hendricks, 2023 Ark. 103 (Ark. 2023).

Denney v. Denney, 2015 Ark. 257 (Ark. 2015).

Sharon Marcum v. Robert Hodge, Special Adm'r of the Est. of Nicholas Hendricks, 2022 Ark. App. 497 (Ark. Ct. App. 2022).

— Ark. Code Ann. § 18-44-115(a)(8)(A) — 3 cases

— Ark. Code Ann. § 18-44-115(a)(8)(B) — 1 case

— Ark. Code Ann. § 18-44-115(a)(l) — 1 case

— Ark. Code Ann. § 18-44-115(b) — 2 cases

Bryant v. Cadena Contracting, Inc., 269 S.W.3d 378 (Ark. Ct. App. 2007). “Appellants James and Aileen Bryant appeal from the December 12, 2006 judgment of the Lonoke County Circuit Court, which found that subcontractors are exempt from the statutory notice requirement contained in Ark.Code Ann. § 18-44-115 (Supp. 2007), and ordered a foreclosure on…”

— Ark. Code Ann. § 18-44-115(b)(1) — 1 case

Bryant v. Jim Atkinson Tile, 269 S.W.3d 383 (Ark. Ct. App. 2007). “This case presents two questions: first, must notice be provided to the property owner under Ark. Code Ann. § 18-44-115 (Supp.2007) before a subcontractor may obtain a valid lien on the property and, second, if the answer to that question is yes, when must notice be provided? We…”

— Ark. Code Ann. § 18-44-115(b)(1)(A) — 2 cases

— Ark. Code Ann. § 18-44-115(b)(1)(B) — 1 case

— Ark. Code Ann. § 18-44-115(b)(4) — 2 cases

Ahern Rentals, Inc. v. Salter Constr., Inc., 2014 Ark. App. 423 (Ark. Ct. App. 2014).

JMAC Farms, LLC v. G & C Generator, LLC, 537 S.W.3d 274 (Ark. Ct. App. 2017).

— Ark. Code Ann. § 18-44-115(b)(5) — 1 case

Florida Oil Inv. Grp., LLC v. Goodwin & Goodwin, Inc., 2016 Ark. App. 380 (Ark. Ct. App. 2016).

— Ark. Code Ann. § 18-44-115(b)(6) — 1 case

Maly Farms, Inc., & Maly Lodging, LLC v. Reynolds Excavating, Inc., 2024 Ark. App. 270 (Ark. Ct. App. 2024).

— Ark. Code Ann. § 18-44-115(b)(6)(A) — 1 case

Ahern Rentals, Inc. v. Salter Constr., Inc., 2014 Ark. App. 423 (Ark. Ct. App. 2014).

— Ark. Code Ann. § 18-44-115(b)(l)(A) — 1 case

Ahern Rentals, Inc. v. Salter Constr., Inc., 2014 Ark. App. 423 (Ark. Ct. App. 2014).

— Ark. Code Ann. § 18-44-115(c) — 2 cases

Cannon Remodeling & Painting, Inc. v. Mktg. CO., 90 S.W.3d 5 (Ark. Ct. App. 2002). “TMC alleged *7 in its counterclaim that it was entitled to damages, alleging that Cannon breached its contract and that Cannon negligently performed the work resulting in damage to the property.”

— Ark. Code Ann. § 18-44-115(d) — 1 case

Westside Galvanizing Servs., Inc. v. Georgia-Pac. Corp. & Se. Conveyor Fabricators, Inc., Aaa Steel Detailing, Inc., Intervenor, 921 F.2d 735 (8th Cir. 1991).

— Ark. Code Ann. § 18-44-115(e) — 3 cases

Westside Galvanizing Servs., Inc. v. Georgia-Pac. Corp. & Se. Conveyor Fabricators, Inc., Aaa Steel Detailing, Inc., Intervenor, 921 F.2d 735 (8th Cir. 1991).

— Ark. Code Ann. § 18-44-115(e)(1) — 1 case

— Ark. Code Ann. § 18-44-115(e)(1)(C) — 1 case

— Ark. Code Ann. § 18-44-115(e)(2) — 3 cases

Ground Zero Constr., Inc. v. Walnut Creek, LLC, 410 S.W.3d 579 (Ark. 2012). “On March 6, 2009, in lieu of answering the complaint, Marrs Electric filed a motion to dismiss Ground Zero’s lien claim, alleging that Ground Zero had not complied with the notice requirements of section 18-44-115 because Ground Zero failed to include a proper description of the…”

— Ark. Code Ann. § 18-44-115(e)(2)(A) — 1 case

— Ark. Code Ann. § 18-44-115(e)(2)(B) — 1 case

— Ark. Code Ann. § 18-44-115(e)(2)(C) — 1 case

— Ark. Code Ann. § 18-44-115(e)(2)(C)(v) — 1 case

— Ark. Code Ann. § 18-44-115(e)(l) — 1 case

— Ark. Code Ann. § 18-44-115(f) — 3 cases

Land O'Frost, Inc. v. Pledger, 823 S.W.2d 887 (Ark. 1992).

— Ark. Code Ann. § 18-44-115(f)(3) — 1 case

Bell-Corley Constr., LLC v. Orange State Realty, Inc., 383 S.W.3d 442 (Ark. Ct. App. 2011).

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