Wesco Distribution, Inc. v. Westport Group, Inc.
Wesco Distribution, Inc., a materialman, appealed a district court's judgment granting Westport Group Inc.'s (general contractor) motion for summary judgment to remove a materialman's lien and awarding Westport attorney's fees. Wesco had supplied materials to J&D Electric, a subcontractor, but was not fully paid. Wesco attempted to send notice of a materialman's lien to Westport, but the initial mailing lacked sufficient postage and was returned, delaying proper notice. Westport had already paid J&D Electric almost everything owed by the time it received Wesco's notice. The appellate court affirmed the district court's decision, holding that Wesco's initial attempt to mail notice with insufficient postage did not constitute timely notice under the Texas materialman’s lien statute, and thus the lien was invalid. The court also upheld the award of attorney's fees to Westport.