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

Mich. Comp. Laws § 570.1106 (2026)

Additional definitions.

✓ current as of July 2026
Find cases: SyfertCases citing this section MI-LEGlegislature.mi.gov JustiaChapter on Justia CornellLII Search CasesGoogle Scholar

CONSTRUCTION LIEN ACT


Act 497 of 1980


570.1106 Additional definitions.

Sec. 106.

    (1) "Person" means an individual, corporation, partnership, association, other legal entity, or any combination of these.

    (2) "Professional services" means services that are customarily and legally performed by or under the supervision or responsible control of design professionals in the course of their professional practice, including, but not limited to, programming, planning, surveying, site investigation, analysis, assessment, design, preparation of drawings and specifications, and construction administration services.

    (3) "Project" means the aggregate of improvements contracted for by the contracting owner.

    (4) "Residential structure" means an individual residential condominium unit or a residential building containing not more than 2 residential units, the land on which it is or will be located, and all appurtenances, in which the owner or lessee contracting for the improvement is residing or will reside on completion of the improvement.

    (5) "Subcontractor" means a person, other than a laborer or supplier, who pursuant to a contract between himself or herself and a person other than the owner or lessee performs any part of a contractor's contract for an improvement.

    (6) "Supplier" means a person who, pursuant to a contract with a contractor or a subcontractor, leases, rents, or in any other manner provides material or equipment that is used in the improvement of real property. Supplier does not include a design professional or a person that has a subcontract with a design professional as described in section 107b.

    (7) "Wages" means all earnings of an employee, whether determined on the basis of time, task, piece, commission, or other method of calculation, for labor or services, except fringe benefits and withholdings.

History: 1980, Act 497, Eff. Jan. 1, 1982 ;-- Am. 1981, Act 191, Eff. Jan. 1, 1982 ;-- Am. 1982, Act 17, Eff. Mar. 1, 1982 ;-- Am. 2006, Act 497, Eff. Jan. 3, 2007 ;-- Am. 2010, Act 147, Imd. Eff. Aug. 23, 2010 ;-- Am. 2018, Act 367, Imd. Eff. Dec. 12, 2018

Notes of Decisions
Cited in 12 cases (2 in the last 5 years), 1987–2024 · leading case: Ronnisch Constr. Grp., Inc v. Lofts on the Nine, LLC, 886 N.W.2d 113 (Mich. 2016).
Sort: Relevance Newest Treatment
Ronnisch Constr. Grp., Inc v. Lofts on the Nine, LLC, 886 N.W.2d 113 (Mich. 2016). · cites it 2× “” 21 While RCG prevailed at arbitration, it did so only on its contract claim, not the lien claim.”
Karaus v. Bank of New York Mellon, 831 N.W.2d 897 (Mich. Ct. App. 2012). ““Residential structure” is defined by the CLA, MCL 570.1106(3), as “an individual residential condominium unit or a residential building containing not more than 2 residential units, the land on which it is or will be located, and all appurtenances, in which the owner or lessee…”
Erb Lumber, Inc v. Gidley, 594 N.W.2d 81 (Mich. Ct. App. 1999). · cites it 2× “Yet under the plain language of the act, an improvement "means the result of labor or material provided by a contractor, subcontractor, supplier, or laborer.”
Titanus Cement Wall Co., Inc. v. Watson, 405 N.W.2d 132 (Mich. Ct. App. 1987). · cites it 3× “"Residential structure” is defined in MCL 570.1106(3); MSA 26.316(106)(3) as an individual residential condominium unit or a residential building containing not more than 2 residential units, the land on which it is or will be located, and all appurtenances thereto, in which the…”
M D Marinich, Inc v. Michigan Nat'l Bank, 484 N.W.2d 738 (Mich. Ct. App. 1992). “"Improvements” is also broadly defined and includes, among other *457 services provided, architectural planning and construction management.”
Dlf Trucking Inc v. Bach, 707 N.W.2d 606 (Mich. Ct. App. 2005). “5 See MCL 570.1106(3), which defines a “residential structure,” against which a hen may not attach under subsection 1 of § 203, as including “a residential building containing not more than 2 residential units, the land on which it is or will be located, and all appurtenances…”
Jeddo Drywall, Inc. v. Cambridge Inv. Grp. Inc., 810 N.W.2d 633 (Mich. Ct. App. 2011). “MCL 570.1106(2) provides that a “project” is “the aggregate of improvements contracted for by the contracting owner.”
Kitchen Suppliers, Inc. v. Erb Lumber Co., 440 N.W.2d 50 (Mich. Ct. App. 1989). · cites it 3× “[MCL 570.1106(3); MSA 26.316 (106X3). Emphasis added.”
Schuster Constr. Servs., Inc. v. Painia Dev. Corp., 651 N.W.2d 749 (Mich. Ct. App. 2002). “Plaintiff is a “supplier,” MCL 570.1106(5), having rented a forklift to Roper for use at the Ariel Square project.”
Michigan Pipe & Valve-Lansing, Inc. v. Hebeler Enter., Inc., 808 N.W.2d 323 (Mich. Ct. App. 2011). “…the owner or lessee contracting for the improvement is residing or will reside upon completion of the improvement.” MCL 570.1106(3).”
Morland Prop. Servs. LLC v. J J Dev. Inc (Mich. Ct. App. 2024). · cites it 5× “[MCL 570.1106(4).] The parties do not appear to dispute the home being built on the subject property was a “residential building.”
Eci Env't Consultants & Engineers v. House of Providence (Mich. Ct. App. 2023). “Both forms of this type of labor involve expert services that provide the owner of the real property with greater insight or options on how to develop their property, and is defined in MCL 570.1106(2): “Professional services” means services that are customarily and legally…”
— Mich. Comp. Laws § 570.1106(1) — 1 case
Ronnisch Constr. Grp., Inc v. Lofts on the Nine, LLC, 886 N.W.2d 113 (Mich. 2016). “” 21 While RCG prevailed at arbitration, it did so only on its contract claim, not the lien claim.”
— Mich. Comp. Laws § 570.1106(2) — 4 cases
Erb Lumber, Inc v. Gidley, 594 N.W.2d 81 (Mich. Ct. App. 1999). “Yet under the plain language of the act, an improvement "means the result of labor or material provided by a contractor, subcontractor, supplier, or laborer.”
M D Marinich, Inc v. Michigan Nat'l Bank, 484 N.W.2d 738 (Mich. Ct. App. 1992). “"Improvements” is also broadly defined and includes, among other *457 services provided, architectural planning and construction management.”
Jeddo Drywall, Inc. v. Cambridge Inv. Grp. Inc., 810 N.W.2d 633 (Mich. Ct. App. 2011). “MCL 570.1106(2) provides that a “project” is “the aggregate of improvements contracted for by the contracting owner.”
Eci Env't Consultants & Engineers v. House of Providence (Mich. Ct. App. 2023). “Both forms of this type of labor involve expert services that provide the owner of the real property with greater insight or options on how to develop their property, and is defined in MCL 570.1106(2): “Professional services” means services that are customarily and legally…”
— Mich. Comp. Laws § 570.1106(3) — 5 cases
Karaus v. Bank of New York Mellon, 831 N.W.2d 897 (Mich. Ct. App. 2012). ““Residential structure” is defined by the CLA, MCL 570.1106(3), as “an individual residential condominium unit or a residential building containing not more than 2 residential units, the land on which it is or will be located, and all appurtenances, in which the owner or lessee…”
Dlf Trucking Inc v. Bach, 707 N.W.2d 606 (Mich. Ct. App. 2005). “5 See MCL 570.1106(3), which defines a “residential structure,” against which a hen may not attach under subsection 1 of § 203, as including “a residential building containing not more than 2 residential units, the land on which it is or will be located, and all appurtenances…”
Titanus Cement Wall Co., Inc. v. Watson, 405 N.W.2d 132 (Mich. Ct. App. 1987). “"Residential structure” is defined in MCL 570.1106(3); MSA 26.316(106)(3) as an individual residential condominium unit or a residential building containing not more than 2 residential units, the land on which it is or will be located, and all appurtenances thereto, in which the…”
Kitchen Suppliers, Inc. v. Erb Lumber Co., 440 N.W.2d 50 (Mich. Ct. App. 1989). “[MCL 570.1106(3); MSA 26.316 (106X3). Emphasis added.”
Michigan Pipe & Valve-Lansing, Inc. v. Hebeler Enter., Inc., 808 N.W.2d 323 (Mich. Ct. App. 2011). “…the owner or lessee contracting for the improvement is residing or will reside upon completion of the improvement.” MCL 570.1106(3).”
— Mich. Comp. Laws § 570.1106(4) — 2 cases
Titanus Cement Wall Co., Inc. v. Watson, 405 N.W.2d 132 (Mich. Ct. App. 1987). “"Residential structure” is defined in MCL 570.1106(3); MSA 26.316(106)(3) as an individual residential condominium unit or a residential building containing not more than 2 residential units, the land on which it is or will be located, and all appurtenances thereto, in which the…”
Morland Prop. Servs. LLC v. J J Dev. Inc (Mich. Ct. App. 2024). “[MCL 570.1106(4).] The parties do not appear to dispute the home being built on the subject property was a “residential building.”
— Mich. Comp. Laws § 570.1106(5) — 3 cases
Schuster Constr. Servs., Inc. v. Painia Dev. Corp., 651 N.W.2d 749 (Mich. Ct. App. 2002). “Plaintiff is a “supplier,” MCL 570.1106(5), having rented a forklift to Roper for use at the Ariel Square project.”
Titanus Cement Wall Co., Inc. v. Watson, 405 N.W.2d 132 (Mich. Ct. App. 1987). “"Residential structure” is defined in MCL 570.1106(3); MSA 26.316(106)(3) as an individual residential condominium unit or a residential building containing not more than 2 residential units, the land on which it is or will be located, and all appurtenances thereto, in which the…”
Kitchen Suppliers, Inc. v. Erb Lumber Co., 440 N.W.2d 50 (Mich. Ct. App. 1989). “[MCL 570.1106(3); MSA 26.316 (106X3). Emphasis added.”
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.