In Bricklayers of Western Pennsylvania Combined Funds, Inc. v. Scott's Development Company, 2012 WL 29299 (Pa. Super.), the Superior Court of Pennsylvania found that the trustees of employment funds had standing to file mechanics' lien claims for unpaid contributions owed to union members as a result of collective bargaining agreements between a contractor and the unions.  The Pennsylvania lien statute is more restrictive than Hawaii's, which allows a "person" who provides materials or labor to a construction project to file a mechanics lien to recover sums due and owing.  In Pennsylvania, standing to file liens is limited to "contractors" or "subcontractors."  Nevertheless, the Pennsylvania court found that the statute must be read expansively in order to effectuate the purpose of protecting pre-payment of labor and materials.  In doing so, the court joined the ranks of Hawaii and a number of other states, including Utah, Minnesota, Connecticutt, Nebraska, Illinois, Arizona, Maryland, and Iowa, in concluding that a trustee of an employment benefit fund has standing to assert a mechanics lien claim.  The case can be found here.