Is a project manager entitled to a lien for his services?

In Marino v. Bay-Walsh Ltd., [2002] O.J. No. 2211 ONSC, Zelinski J. observed: 110. When there has been a price agreed upon the person who has provided services or materials is (absent abandonment) entitled to a lien for that price for those services or materials. It is the price that has been agreed upon and the requirement that those services or materials be supplied “to the improvement” which defines the eligibility for and quantum of the lien claim. 111. Project managers whose responsibilities, whether onsite or off contributed “in a direct and essential way to the construction of the improvement” are persons who have supplied services “to the improvement” whether or not the services are supervisory, managerial, physical or manual.