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LINCOLN COUNTY • CJ-2026-00050

AJ Jones Construction, LLC v. Michael D. Culie and Sarah C. Culie, husband and wife

Filed: Apr 6, 2026
Type: CJ
View Official Docket ↗

What's This Case About?

Let’s be honest—nobody expects a $14,500 construction dispute to involve county commissioners, a bank, and the county treasurer all being dragged into court like they’re extras in a low-budget legal thriller. But here we are, folks, in Lincoln County, Oklahoma, where a home build gone sideways has turned into a full-blown property lien circus, and the ringmaster is a contractor named Adam Jones III—better known as A.J. Jones, owner of A.J. Jones Construction, LLC. He’s not just suing the homeowners; he’s suing the entire food chain of property ownership, from the couple who hired him to the bank that might own the mortgage, to the county itself, just in case someone forgot to pay their property taxes. This isn’t just a lawsuit—it’s a property rights takedown tour.

So who are these people? On one side, you’ve got Adam Jones III—self-described as both an individual and a business (because in Oklahoma, apparently, you can be two things at once: a man and an LLC). He runs his construction gig out of Eufaula, a small town where the biggest drama usually involves whose cow got loose at the county fair. On the other side, you’ve got Michael and Sarah Culie, a married couple trying to build their dream home somewhere near Perkins, Oklahoma—a place so quiet, the most exciting thing that happens is when the wind changes direction. They hired Jones to build their house, signed a contract in May 2024, and for a while, everything was going great. Payments were made. Concrete was poured. Windows were installed. It was all very This Old House, until suddenly, it wasn’t.

Here’s how it all fell apart. According to the filing, the Culies and Jones had a payment schedule: $75,000 upfront to get things rolling, then $50,000 when the concrete work was done. Then came reimbursements—$10,000 for windows, $2,000 for partial back doors (because apparently, one back door wasn’t enough?), and another $10,500 for some mysterious “add change order” that sounds like it came out of a Sims gameplay glitch. Then came the $30,000 payment for framing and metal—basically, the skeleton of the house. All good so far. But when it came time for the final $19,250, things went quiet. Radio silence. No check. No explanation. Just a growing silence that echoed louder than a hammer on an empty job site.

Jones says he did the work. The Culies, allegedly, just stopped paying. And not only did they not pay—they didn’t even talk to him about it. So, being a man who believes in documentation, Jones did what any self-respecting contractor in Oklahoma would do: he filed a mechanics lien. That’s a legal “Hey, I built this, and if you don’t pay me, I get to claim part of the property” card. He filed it in April 2025, claiming $14,500 was still owed after deducting $4,000 for partial back doors and $750 because, apparently, the Culies provided one back door themselves—because nothing says “I’m saving money” like sourcing your own exterior door like it’s a DIY Pinterest project.

Now, here’s where it gets juicy. Jones isn’t just suing the Culies. He’s suing everyone who might have a claim on that land. Why? Because when you file a mechanics lien, you’re basically jumping into the property ownership food chain, and you want to know your place in line. So Jones drags in the Board of County Commissioners of Lincoln County and Brenda Jackson, the county treasurer, just in case they’re holding some unpaid tax lien that could mess up his claim. And then—because why not?—he also sues BancFirst in Stillwater, because there’s a mortgage on the property, and he needs to know if the bank is going to swoop in and claim it all before he gets a dime.

In plain English: Jones is saying, “I built this house. I got paid for most of it. But $14,500 is still missing. I put a lien on the property so I can get paid if they sell it. But before I can collect, I need to know who else is in line ahead of me—tax collectors? The bank? The ghost of a former landowner? So everyone, show your cards.”

And what does he want? $14,500. Plus interest. Plus attorney fees. And, if the Culies still won’t pay, he wants the court to sell the house—or at least the portion covered by his lien—to get his money. Now, is $14,500 a lot? In the world of home construction, not really. That’s less than the cost of a mid-range HVAC system. But for a couple building a house in rural Oklahoma, it’s not nothing. And for a contractor who’s already done the work, it’s not just about the money—it’s about the principle. It’s about not getting ghosted after hauling metal beams and framing walls in the Oklahoma heat.

But here’s the real kicker: Jones is suing in personam and in rem. That’s lawyer-speak for “I’m suing the people, and I’m also suing the land itself.” Yes, the land is on trial. In legal terms, this means he’s not just trying to get a judgment against the Culies personally—he’s trying to attach that judgment directly to the property, so even if they sell it, he gets paid. It’s like putting a curse on the land that says, “No sale until A.J. gets his $14,500.”

Our take? This case is equal parts petty and brilliant. On one hand, $14,500 is not a fortune—especially in construction, where one mis-measured beam can cost more than that. But on the other hand, the way Jones is going about it is kind of amazing. He didn’t just send a demand letter. He didn’t just file a small claims case. No, he went full legal Godzilla, stomping through Lincoln County, roaring at the county government, the bank, and the homeowners all at once. He’s not just protecting his paycheck—he’s making a statement: You don’t walk away from a job site without paying the man who built your walls.

And honestly? We’re rooting for him. Not because the Culies are definitely in the wrong—because we don’t know that for sure—but because someone has to stand up for the little guy who shows up with a toolbox and leaves with an unpaid invoice. This isn’t just about $14,500. It’s about respect. It’s about not letting people treat contractors like disposable labor. And if that means dragging the county treasurer into it just to make a point? Well, then bring on the subpoenas.

So will the court force the sale of the Culies’ dream home over a back door and $14,500? Probably not. These cases usually settle. But the fact that Jones had the guts to file this—naming everyone, citing everything, and demanding justice with appraisement—is the kind of drama we live for. This isn’t just a civil dispute. It’s a statement. And in the quiet fields of Lincoln County, sometimes a statement is worth every penny.

Case Overview

$14,500 Demand Petition
Jurisdiction
District Court 23rd Judicial District, Oklahoma
Filing Attorney
James J. Hodgens
Relief Sought
$14,500 Monetary
Plaintiffs
Defendants
Claims
# Cause of Action Description
1 breach of contract Plaintiff seeks payment for construction services rendered to Defendants.

Petition Text

1,749 words
IN THE DISTRICT COURT TWENTY THIRD JUDICIAL DISTRICT SITTING IN LINCOLN COUNTY, OKLAHOMA ADAM JONES, III., A.K.A., A.J. JONES, D.B.A., A.J. JONES CONSTRUCTION, LLC, An Oklahoma Limited Liability Company, PLAINTIFFS, V. GROUP I: MICHAEL D. CULIE, A.K.A. MICHAEL CULIE AND SARAH CULIE, HUSBAND AND WIFE, AND GROUP II: THE BOARD OF COUNTY COMMISSIONERS OF LINCOLN COUNTY, OKLAHOMA; BRENDA JACKSON, TREASURER OF LINCOLN COUNTY, OKLAHOMA, AND, GROUP III: BANCFIRST, STILLWATER, OKLAHOMA, DEFENDANTS. CASE NO.: CD-26-50 PETITION COMES NOW the Plaintiff, Adam Jones III, a.k.a, A.J. Jones, d.b.a., A.J. Jones Construction, LLC., an Oklahoma Limited Liability Company, and for this their Cause of Action against the Defendants, and each of them, would state and allege as follows: 1. That the Plaintiff, Adam Jones, III, a.k.a., A.J., Jones, d.b.a., A.J. Jones Construction, LLC is a limited liability company with its offices and principal place of business located in Eufaula, Oklahoma. 2. That this Court has venue and jurisdiction over the parties and subject matter hereof for the reason that the real property, which is the subject matter of this cause of action, is located within the territorial boundaries of Lincoln County, Oklahoma. 3. That on or about May 9, 2024 the Plaintiff and the Group I Defendants, Michael D. Culie and Sarah C. Culie, husband and wife (from hereinafter "Group I Defendants") executed a contract with the Plaintiffs to construct a home on property owned by the Group I Defendants in Lincoln County, Oklahoma. That the Plaintiff initiated construction and received partial payment for work performed. Thereafter the Group I Defendants failed and refused to pay Plaintiff the balance of the amounts due and owing under the contract and as such, breached the contract. 4. That the Plaintiff filed its Mechanics and Materialman's Lien in the Office of the County Clerk of Lincoln County, Oklahoma on or about April 9, 2025 same to be filed against the following described real property: LINCOLN COUNTY, OKLAHOMA: A part of the East Half of the Southwest Quarter (E/2 SW/4) of Section Nine (9), Township Sixteen (16) North, Range Two (2) East of the Indian Meridian, Lincoln County, Oklahoma, being more particularly described as follows: Commencing at the SW/c of Section 9, thence N 89°03'14" E along the South line of the SW/4 a distance of 1324.15 feet to the SW/c of the E/2 SW/4 for a point of beginning; thence N 00°23'45" E along the West line of the E/2 SW/4 a distance of 2021.01 feet; thence N 89°09'53" E a distance of 339.76 feet; thence S 00°22'48" W a distance of 1390.34 feet; thence S 89°03'14" W a distance of 38.26 feet to a found 1/2" pin; thence S 00°22'48" W a distance of 630.00 feet to the South line of the SW/4; thence S 89°03'14" W along the South line of the SW/4 a distance of 302.08 feet to the point of beginning, less and except all oil, gas and other minerals. MECHANICS LIEN: Dated: March 17, 2025 Filed: April 9, 2025 Recorded: Book 2599 at Page 675 The above described mechanic's lien being made a part hereof and attached herewith as Plaintiff's "Exhibit A". 5. That the Group I Defendants, have breached the contract to construct the structure on the real property in question and demand has been made by the said Plaintiff, but that the Defendants have failed, refused and neglected to pay the amounts due and owing. That all sums are currently due and owing and that the Plaintiff is in all respects entitled to a judgment against the Group I Defendants, for the sum of $14,500.00 with interest accruing from and after the date of filing until paid together with a reasonable attorney fee as provided for by statute. 6. That the Group II Defendants, Board of County Commissioners of Lincoln County, Oklahoma, and Brenda Jackson, as Lincoln County Treasurer, may be claiming some right, title, interest, estate or equity in and to the said property by virtue of certain ad valorem tax or personal property tax liens covering the subject property. That said Defendants should be required to appear and set forth the nature and interest of any taxes due on the property so that lien priorities may be determined and, in failing to appear, should be determined to have no right, title, interest, estate or equity in the subject property. 7. That the Group III Defendant, BancFirst, Stillwater, Oklahoma may be claiming some right, title, interest, estate or equity in the subject property by virtue of a certain mortgage lien filed at Book 2556 at Page 1 and Book 2510 at Page 15 in the Office of the County Clerk of Lincoln County, Oklahoma and as such said Defendant should be summoned to appear and set forth what right, title, interest, estate or equity they claim in the subject property for purposes of determining lien priority. WHEREFORE, premises considered, the Plaintiff requests this Court to summon the Defendants to file their answers herein setting forth their interest, if any they have, in and to the above described real estate; that the Court should enter judgment in favor of the Plaintiff and as against the Group I Defendants, MICHAEL D. CULIE, A.K.A., MICHAEL CULIE AND SARAH C. CULIE, husband and wife, in personam and in rem, for the sum of $14,500.00 with accruing interest on the principal sum claimed due and owing until paid and, as against all other Defendants determining their interest in the subject property, and enter an in rem judgment only as it pertains to the Group II Defendants, Board of County Commissioners of Lincoln County, Oklahoma, Brenda Jackson, as Lincoln County Treasurer, and the Group III Defendant, BancFirst, Stillwater, Oklahoma, and grant the the Plaintiff the costs of this action, including a reasonable attorney fee as provided for by statute; that said real property be ordered to be sold to satisfy the judgment of the Plaintiff, said sale to be with appraisement plus grant the Plaintiff whatever and further relief as is just and equitable in the premises. ELECTION OF SALE WITH APPRAISEMENT The Plaintiff elects to have the real property described herein sold, with appraisement, as provided by law. Respectfully submitted, JAMES J. HODGENS, P. C. [Signature] James J. Hodgens, OBA #10338 P. O. Box 686 Stroud, OK 74079 918/968-2537 Fax: 918/968-2620 Attorney for Plaintiff VERIFICATION STATE OF OKLAHOMA ) COUNTY OF LINCOLN ) SS: James J. Hodgens of lawful age, being first fully sworn upon oath, deposes and states that he is the Plaintiff's attorney in the above entitled cause of action; that he has read the above and foregoing pleading and knows the contents thereof; that the allegations contained in said pleading are true and correct according to his best knowledge and belief. Dated this 2nd day of April, 2026, at Stroud, Lincoln County, Oklahoma. [Signature] James J. Hodgens Sworn to and signed before me, a notary public, in and for the State of Oklahoma. CATHY RAMSEY NOTARY PUBLIC #17006011 EXP. 06/29/2029 STATE OF OKLAHOMA Cathy Ramsey, Notary Public Commission Number: 17006011 Commission Expires: 6.29.29 Mechanic’s Lien Statement of Claim SAI 4064 (2024) STATE OF OKLAHOMA ) ) SS COUNTY OF LINCOLN ) Known all men by these presents: I, ADAM JONES III (AKA AJ JONES), have a claim against Michael and Sarah Culie for the sum of $14,500 dollars ($:00) due to me, and that the claim is made for and on account of AJ Jones Construction, LLC and that such work was performed and materials supplied by me the 17th day of March, 2025 according to an itemized statement thereof, hereto attached marked "Exhibit A" and make part of this statement; that such work, labor, and materials were done in pursuance of a contract with Adam Jones III (aka AJJones) owner/operator of AJ Jones Construction, LLC and was performed upon the building and premises owned by Michael and Sarah Culie And described as follows to wit: (LEGAL DESCRIPTION) 331290 E Hwy 105 Wellston, Ok 74881 see attached "exhibit B" for legal description In said County and State; that the sum is just due and unpaid, and I have claimed a lien upon said building and upon the said premises on which the same is situated, to the amount of $14,500.00 as above set forth, according to the laws of the State of Oklahoma. Dated this 17th day of March, 2025. SIGNATURE OF CLAIMANT Note: Attach itemized statement STATE OF OKLAHOMA ) SS COUNTY OF Lincoln ) Adam Jones III, of lawful age, being first duly sworn upon oath, says: That he/she is the claimant mentioned in the foregoing Statement of Mechanic's Lien; that he/she had read said statement and knows the contents thereof; that the name of the owner, name of the contractor, the name of the claimant, the description of the property upon which the lien is claimed, and the items of the account as therein set forth, are just, true, and correct. [signature] SIGNATURE OF CLAIMANT Subscribed and sworn to before me this 4 day of April, 2025. My commission expires: 1-30-27 Commission #: 11000CAu Revised 11/2024 "EXHIBIT A" Jones Construction (918)-689-0901 408401 E 1130 Rd Eufaula, Ok 74432 Michael and Sarah Culie [email protected] Location of Work: Perkins, Oklahoma 405-269-7144 1st payment Build startup $75,000.00 Paid 2nd payment Completion Concrete $50,000.00 Paid Reimbursement windows $10,000.00 Paid Reimbursement partial back doors. $2,000.00 Paid Add change order. $10,500.00 Paid 3rd payment Framing and metal $30,000.00 Paid 4th Final $19,250.00 Deduct, partial back doors. $4,000.00 Deduct, back door provided by owner. $750.00 Total due $14,500.00 "EXHIBIT B" Apart of the East Half of the Southwest Quarter (E½ SW¼) of Section Nine (9), Township Sixteen (16) North, Range Two (2) East of the Indian Meridian, Lincoln County, Oklahoma, being more particularly described as follows: Commencing at the SW/c of Section 9; thence N 89°03'14" E along the South line of the SW¼ a distance of 1324.15 feet to the SW/c of the E½ SW¼ for a point of beginning; thence N 00°23'45" E along the West line of the E½ SW¼ a distance of 2021.01 feet; thence N 89°09'53" E a distance of 339.76 feet; thence S 00°22'48" W a distance of 1390.34 feet; thence S 89°03'14" W a distance of 38.26 feet to a found ½" pin; thence S 00°22'48" W a distance of 630.00 feet to the South line of the SW¼; thence S 89°03'14" W along the South line of the SW¼ a distance of 302.08 feet to the point of beginning, less and except all oil, gas and other minerals. STATE OF OKLAHOMA } ss COUNTY OF LINCOLN } I, ALICIA WAGNON, County Clerk, do hereby certify that the foregoing is a true and correct copy of a like instrument now on file in my office. Witness my hand and official seal this day of March 2020 Alicia Wagner COUNTY CLERK BY Deputy
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