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P.H.A.C. Services, Inc. v. Seaways International, Inc.
Louisiana Supreme Court
403 So. 2d 1199 (1981)
Facts
P.H.A.C. Services, Inc. and Acoustical Spray Insulators, Inc. (subcontractors) (plaintiffs) were subcontractors who provided labor and materials for the construction of a living-quarters structure for an offshore-drilling platform. The structure was built on land on blocks and later moved to the platform. The platform was owned by Pennzoil Company, and the general contractor for the project was Seaways International, Inc. (defendants). The subcontractors completed their work in accordance with their contracts but were never paid. The subcontractors sued Pennzoil and Seaways. The subcontractors sought to assert lien privileges against the structure in reliance on a number of different state statutes, including the Private Works Act. The Private Works Act provided protections for workers who supplied labor or materials for the construction of immovable property. The trial court ruled that the subcontractors did not have a claim under the Private Works Act, holding that the structure was not in fact a building and not immovable property. The court of appeal reversed the trial court’s decision, holding that the structure was in fact a building and that the Private Works Act applied. Both parties requested a writ of certiorari from the Louisiana Supreme Court.
Rule of Law
Issue
Holding and Reasoning (Dixon, C.J.)
Concurrence (Marcus, J.)
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