I think that would be the ONLY argument you could make in support of filing a mechanic's lien, but I think it is quite a stretch.  If that were the case, Black and Decker could file a lien against you if you bought a power saw from Home Depot and Home Depot didn't pay them for it. 

Think about it... the power tool was going to be used to make home improvements.

Its also quite an assumption that every title search results in a home improvement.  Most arguably do not.  Most of the searches are for purchases, refinances to consolidate debt or get a lower rate, or foreclosures.  The link between a title search and a home improvement is tenuous at best.

In interpreting a statute, you look first at the plain language of the statute.  I think that would cut against the filing of a mechanic's lien for a title search.  If there is ambiguity, which you seem to find, then you would look at the intent of the statute.  I don't think you will find any intent to cover such a situation, but I haven't reviewed the congressional notes from its enactment.

The intent of the statute seems clear to me.  It is to provide for a lien for contractors and suppliers who actually contribute directly to the home improvement. 

To dissect the statute a bit further... it only entitles a "person who performs work or labor upon or furnishes material in furtherance of any home improvement."  A title search is definitely not material so it would have to work or labor performed upon the improvement.  I don't think a title search would qualify there either. 

It is a nice argument, but I wouldn't try it without an attorney willing to go to court for you in a slander of title suit.  And... I'm not a lawyer and I haven't had any classes that discussed mechanic's liens.  I could be wrong.  Does anyone out there want to roll the dice and make some new case law on the subject?

Best,
Robert A. Franco
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