Florida Statutes
Fla. Stat. § 713.09 (2025)
Single claim of lien.
✓ 2025 Florida Statutes — current through the 2025 Regular Session
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713.09 Single claim of lien.—A lienor is required to record only one claim of lien covering his or her entire demand against the real property when the amount demanded is for labor or services or material furnished for more than one improvement under the same direct contract. The single claim of lien is sufficient even though the improvement is for one or more improvements located on separate lots, parcels, or tracts of land. If materials to be used on one or more improvements on separate lots, parcels, or tracts of land under one direct contract are delivered by a lienor to a place designated by the person with whom the materialman contracted, other than the site of the improvement, the delivery to the place designated is prima facie evidence of delivery to the site of the improvement and incorporation in the improvement. The single claim of lien may be limited to a part of multiple lots, parcels, or tracts of land and their improvements or may cover all of the lots, parcels, or tracts of land and improvements. In each claim of lien under this section, the owner under the direct contract must be the same person for all lots, parcels, or tracts of land against which a single claim of lien is recorded.
History.—s. 1, ch. 63-135; s. 8, ch. 65-456; s. 35, ch. 67-254; s. 6, ch. 80-97; s. 5, ch. 90-109; s. 805, ch. 97-102.
Note.—Former s. 84.091.
Notes of Decisions
Cited in 7
cases, 1976–2013 · leading case: IberiaBank v. Coconut 41, LLC, 984 F. Supp. 2d 1283 (M.D. Ala. 2013).
IberiaBank v. Coconut 41, LLC, 984 F. Supp. 2d 1283 (M.D. Ala. 2013). “A single claim of lien was not appropriate under Fla. Stat. § 713.09 because the properties were owned by different owners.”
Lee v. All Florida Const. Co., 662 So. 2d 365 (Fla. 4th DCA 1995). “" § 713.09, Fla. Stat. (1993). However, where the arrangements between the owner and the contractor for various projects do not arise from the "same direct contract," a single claim of lien is improper.”
Kettles v. Charter Mortg. Co., 337 So. 2d 1012 (Fla. 3d DCA 1976). “The controlling question on this appeal is whether the plaintiff lienor, who is the appellant here, perfected a blanket lien, pursuant to Fla. Stat. § 713.09 (1), [1] upon several, separate lots.”
Florida East Coast Props., Inc. v. COASTAL CONST. Prods., INC., 553 So. 2d 705 (Fla. 3d DCA 1989). “Coastal also argues that over-the-counter sales constitute delivery "by a lienor to a place designated by the person with whom the materialman contracted," § 713.09, Fla. Stat. (1987), so as to bring the twenty-one sales within the separate site provision of the statute.”
Oolite Indus., Inc. v. MILLMAN CONST. CO., 501 So. 2d 655 (Fla. 3d DCA 1987). “The question of recovery for specially fabricated items occurs when they are not incorporated into the improvement.”
Hollywood Appliances, Inc. v. Rutenberg, 541 So. 2d 1283 (Fla. 4th DCA 1989). “An important issue before the trial court was whether the contract between the parties constituted a “same direct contract” as contemplated by section 713.09, Florida Statutes (1987). An affirmative holding on this issue would permit appellant to file a single claim for…”
Seidle v. Reesmar Sales & Millwork Corp. (In re 18th Avenue Dev. Corp.), 5 B.R. 533 (Bankr. S.D. Florida 1980). “F.S. 713.09 contains a specific provision for those circumstances when a single claim of lien is sufficient.”
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