On April 17, 2014, the Supreme Court of Pennsylvania issued a decision in Bricklayers of Western Pennsylvania Combined Funds, Inc. v. Scott's Development Company, et al., that held that union workers (employees of the primary contractor) were not "subcontractors" as that term is defined in the Pennsylvania's Mechanics' Lien Law of 1963, and that trustees of the union's employee benefits trust funds were not entitled to file mechanic's lien claims on the employees' behalf for unpaid contributions to the trust funds.

Following this ruling, Rep. William Keller, D-Philadelphia, introduced HB 2319 to the General Assembly which would amend the Mechanic’s Lien Law to classify union benefit fund trustees as subcontractors allowed to pursue claims for non-payment against employers and property owners under the Mechanic’s Lien Law.