ARS 33-993(A) Interpretation
In S.K. Drywall, Inc. v. Developers Fin. Group, Inc., 169 Ariz. 345, 349, 819 P.2d 931, 935 (1991), the Arizona Supreme Court rejected the argument that a mechanic's lien must be filed after each building in a condominium development was completed.
Because the parties contemplated a "single project," it held there was only one "improvement" under the meaning of A.R.S. 33-993(A). Id. at 353, 819 P.2d at 939.
Therefore, the lien was timely "filed within the statutory period dating from the time the last item of work was performed or the last material was furnished." Id. (citing Gene v. McVety, Inc. v. Don Grady Homes, Inc., 119 Ariz. 482, 484, 581 P.2d 1132, 1134 (1978) ("When work is done or materials furnished, all going to the same general purpose, if the several parts form an entire whole or are so connected together as to show that the parties had it in contemplation that the whole would form but one and not distinct matters of settlement, the whole must be treated as a single contract.")).