Reliance National Indemnity Company, L&T, J v. and Lamar Construction, Inc. v. Advance'd Temporaries, Inc.
This case addresses whether a temporary employment agency, Advance’d Temporaries, Inc., 'furnishes labor' under Chapter 53 of the Texas Property Code, thereby qualifying for a mechanic's lien. The dispute arose from Advance’d supplying workers to a subcontractor, Gonzalez Construction, for a project overseen by general contractor Lamar Construction, Inc. After Gonzalez failed to pay Advance’d, Advance’d claimed a mechanic's lien, which the trial court denied but the court of appeals reversed. The Supreme Court of Texas affirmed the court of appeals, holding that Advance’d did furnish labor because it acted as the employer of the temporary workers, responsible for their hiring, payment, and insurance, despite not controlling their daily work. The Court rejected the application of the borrowed-employee doctrine in this contractual context, affirming Advance'd's entitlement to a mechanic's lien.