I.  Introduction

A claim of lien is an encumbrance against real property created by state law for the purpose of securing payment for labor, materials, or services expended to improve the real property. While there are many types of liens, the most important class of liens to contractors and subcontractors working in Florida were traditionally

Florida courts continue to issue interesting and informative opinions about awards of costs and attorney’s fees in construction lien cases.  Most recently, Florida’s Second District Court of Appeal issued an en banc opinion in the consolidated cases of Richard O. Wolfe, II and H. Michelle Wolfe v. Culpepper Constructors, Inc., Case No. 2D10-3228 and