Mich. Comp. Laws » Michigan Compiled Laws / Chapter 570 / Act 497 of 1980
Michigan Compiled Laws

Mich. Comp. Laws § 570.1103 (2026)

Definitions.

✓ current as of July 2026
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CONSTRUCTION LIEN ACT


Act 497 of 1980


570.1103 Definitions.

Sec. 103.

    (1)  "Actual physical improvement" means the actual physical change in, or alteration of, real property as a result of labor provided, pursuant to a contract, by a contractor, subcontractor, or laborer which is readily visible and of a kind that would alert a person upon reasonable inspection of the existence of an improvement. Actual physical improvement does not include that labor which is provided in preparation for that change or alteration, such as surveying, soil boring and testing, architectural or engineering planning, or the preparation of other plans or drawings of any kind or nature. Actual physical improvement does not include supplies delivered to or stored at the real property.

    (2) "Co-lessee" means a person having an interest in real property, the nature of which is identical to that of the interest of the lessee who contracted for the improvement to the real property, whether the extent of such interest is identical or not.

    (3) "Construction lien" means the lien of a contractor, subcontractor, supplier, or laborer, as described in section 107.

    (4) "Contract" means a contract, of whatever nature, for the providing of improvements to real property, including any and all additions to, deletions from, and amendments to the contract.

    (5) "Contractor" means a person who, pursuant to a contract with the owner or lessee of real property, provides an improvement to real property.

    (6) "Co-owner" means a person having an interest in real property, the nature of which is identical to that of the interest of the owner who contracted for the improvement to the real property, whether the extent of such interest is identical or not.

History: 1980, Act 497, Eff. Jan. 1, 1982 ;-- Am. 1981, Act 191, Eff. Jan. 1, 1982 ;-- Am. 1982, Act 17, Eff. Mar. 1, 1982

Notes of Decisions
Cited in 26 cases (8 in the last 5 years), 1987–2025 · leading case: Stokes v. Millen Roofing Co., 649 N.W.2d 371 (Mich. 2002).
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Stokes v. Millen Roofing Co., 649 N.W.2d 371 (Mich. 2002). · cites it 2× “" MCL 570.1103(5). Millen built a slate roof pursuant to a contract with the owners.”
C D Barnes Assocs. Inc. v. Star Heaven, LLC, 834 N.W.2d 878 (Mich. Ct. App. 2013). · cites it 2× “” MCL 570.1103(4). 3 All the evidence presented below indicated that Barnes was retained, on a time-and-materials basis, to serve as the *420 general contractor for the entire project being undertaken at the property by Star Heaven.”
Alan Custom Homes, Inc v. Krol, 667 N.W.2d 379 (Mich. Ct. App. 2003). “” 5 MCL 570.1103(4) states: “Contract” means a contract, of whatever nature, for the providing of improvements to real property, including any and all additions to, deletions from, and amendments to the contract.”
M D Marinich, Inc v. Michigan Nat'l Bank, 484 N.W.2d 738 (Mich. Ct. App. 1992). · cites it 2× “MCL 570.1103(1); MSA 26.316(103)(1). The Construction Lien Act was enacted as 1980 PA 497 .”
Jeddo Drywall, Inc. v. Cambridge Inv. Grp. Inc., 810 N.W.2d 633 (Mich. Ct. App. 2011). · cites it 2× “The phrase “actual physical improvement” is defined in MCL 570.1103(1), which provides: “Actual physical improvement” means the actual physical change in, or alteration of, real property as a result of labor provided, pursuant to a contract, by a contractor, subcontractor, or…”
Michigan Pipe & Valve-Lansing, Inc. v. Hebeler Enter., Inc., 808 N.W.2d 323 (Mich. Ct. App. 2011). · cites it 6× “Relevant to this appeal, the issues were whether the well drilled days before the recording of Firstbank’s mortgage constituted an “actual physical improvement” under MCL 570.1103(1) and whether MPV could recover service charges as provided in its contract with Hebeler.”
Michigan Bank-Midwest v. D J Reynaert, Inc, 419 N.W.2d 439 (Mich. Ct. App. 1988). “We deem these defendants to be "contracting parties” within the meaning of MCL 570.1103(4); MSA 26.316(103)(4), since they contracted with a series of contractors to build the necessary restaurant facilities.”
Deep South Sys., Inc. v. Heath, 843 So. 2d 378 (Fla. 2d DCA 2003). “' MCL 570.1103(5). Millen built a slate roof pursuant to a contract with the owners.”
Schuster Constr. Servs., Inc. v. Painia Dev. Corp., 651 N.W.2d 749 (Mich. Ct. App. 2002). “Roper is a “contractor,” MCL 570.1103(5), having provided rough carpentry services pursuant to its contract with defendant.”
Titanus Cement Wall Co., Inc. v. Watson, 405 N.W.2d 132 (Mich. Ct. App. 1987). “MCL 570.1103(5); MSA 26.316(103)(5) provides: "Contractor” means a person who, pursuant to a contract with the owner or lessee of real property, provides an improvement to real property.”
In Re Brown, 287 B.R. 676 (E.D. Mich. 2001). “" § 570.1103(4). [7] The term "improvement" as contemplated under the Lien Act means "the result of labor or material provided by a contractor .”
Kitchen Suppliers, Inc. v. Erb Lumber Co., 440 N.W.2d 50 (Mich. Ct. App. 1989). “” MCL 570.1103(5); MSA 26.316(103X5). An "owner” is a "person holding a fee interest in real property or an equitable interest arising out of a land contract.”
Show all 26 citing cases →
— Mich. Comp. Laws § 570.1103(1) — 4 cases
Jeddo Drywall, Inc. v. Cambridge Inv. Grp. Inc., 810 N.W.2d 633 (Mich. Ct. App. 2011). “The phrase “actual physical improvement” is defined in MCL 570.1103(1), which provides: “Actual physical improvement” means the actual physical change in, or alteration of, real property as a result of labor provided, pursuant to a contract, by a contractor, subcontractor, or…”
Michigan Pipe & Valve-Lansing, Inc. v. Hebeler Enter., Inc., 808 N.W.2d 323 (Mich. Ct. App. 2011). “Relevant to this appeal, the issues were whether the well drilled days before the recording of Firstbank’s mortgage constituted an “actual physical improvement” under MCL 570.1103(1) and whether MPV could recover service charges as provided in its contract with Hebeler.”
M D Marinich, Inc v. Michigan Nat'l Bank, 484 N.W.2d 738 (Mich. Ct. App. 1992). “MCL 570.1103(1); MSA 26.316(103)(1). The Construction Lien Act was enacted as 1980 PA 497 .”
Eci Env't Consultants & Engineers v. House of Providence (Mich. Ct. App. 2023).
— Mich. Comp. Laws § 570.1103(3) — 3 cases
Quantum Concrete Inc v. Plaza De Kaza LLC (Mich. Ct. App. 2023).
Keith Gipfert v. Hartford Fire Ins. Co. (Mich. Ct. App. 2024).
20250218_C367762_120_367762.Opn.Pdf (Mich. Ct. App. 2025).
— Mich. Comp. Laws § 570.1103(4) — 12 cases
C D Barnes Assocs. Inc. v. Star Heaven, LLC, 834 N.W.2d 878 (Mich. Ct. App. 2013). “” MCL 570.1103(4). 3 All the evidence presented below indicated that Barnes was retained, on a time-and-materials basis, to serve as the *420 general contractor for the entire project being undertaken at the property by Star Heaven.”
Alan Custom Homes, Inc v. Krol, 667 N.W.2d 379 (Mich. Ct. App. 2003). “” 5 MCL 570.1103(4) states: “Contract” means a contract, of whatever nature, for the providing of improvements to real property, including any and all additions to, deletions from, and amendments to the contract.”
Michigan Bank-Midwest v. D J Reynaert, Inc, 419 N.W.2d 439 (Mich. Ct. App. 1988). “We deem these defendants to be "contracting parties” within the meaning of MCL 570.1103(4); MSA 26.316(103)(4), since they contracted with a series of contractors to build the necessary restaurant facilities.”
M D Marinich, Inc v. Michigan Nat'l Bank, 484 N.W.2d 738 (Mich. Ct. App. 1992). “MCL 570.1103(1); MSA 26.316(103)(1). The Construction Lien Act was enacted as 1980 PA 497 .”
In Re Brown, 287 B.R. 676 (E.D. Mich. 2001). “" § 570.1103(4). [7] The term "improvement" as contemplated under the Lien Act means "the result of labor or material provided by a contractor .”
— Mich. Comp. Laws § 570.1103(5) — 8 cases
Stokes v. Millen Roofing Co., 649 N.W.2d 371 (Mich. 2002). “" MCL 570.1103(5). Millen built a slate roof pursuant to a contract with the owners.”
Deep South Sys., Inc. v. Heath, 843 So. 2d 378 (Fla. 2d DCA 2003). “' MCL 570.1103(5). Millen built a slate roof pursuant to a contract with the owners.”
Schuster Constr. Servs., Inc. v. Painia Dev. Corp., 651 N.W.2d 749 (Mich. Ct. App. 2002). “Roper is a “contractor,” MCL 570.1103(5), having provided rough carpentry services pursuant to its contract with defendant.”
Titanus Cement Wall Co., Inc. v. Watson, 405 N.W.2d 132 (Mich. Ct. App. 1987). “MCL 570.1103(5); MSA 26.316(103)(5) provides: "Contractor” means a person who, pursuant to a contract with the owner or lessee of real property, provides an improvement to real property.”
Kitchen Suppliers, Inc. v. Erb Lumber Co., 440 N.W.2d 50 (Mich. Ct. App. 1989). “” MCL 570.1103(5); MSA 26.316(103X5). An "owner” is a "person holding a fee interest in real property or an equitable interest arising out of a land contract.”
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.