Florida law governs who can enforce a construction lien. Under
the construction lien statute, a contractor, a subcontractor, a
sub-subcontractor, a material man who contracts with an owner, a
contractor, subcontractor, or sub-subcontractor; a laborer, or a
"professional lienor" are entitled to enforce a
construction lien under the statute. Fla. Stat. §
713.01(18).
A valid license is necessary in order for a contractor,
subcontractor, or sub-subcontractor to enforce a construction lien.
Fla. Stat. § 713.02(7). However, there is no license
requirement with regard to providers of material. In
Architectural Complements, Inc. v. R.G. Brown Properties,
Inc., 686 So. 2d 678 (Fla. 2d DCA 1996), the Court found that
issues of material fact precluded a summary judgment in favor of a
developer where a cabinet maker claimed to have acted as a
materialman rather than a subcontractor. The court held that if the
cabinet maker was found to be a materialman rather than
