This section is from the book "The Law Of Real Property and Other Interests In Land", by Herbert Thorn Dike Tiffany. Also available from Amazon: A Treatise on the Modern Law of Real Property and Other Interests in Land .
The equitable right of a bona fide occupant of land to an allowance for improvements made by him is, as has been stated, secured by courts of equity by the establishment of an equitable lien on the land for the amount thereof.29 The statutes likewise, in providing for compensation for improvements made by an occupying claimant,30 sometimes provide expressly or by implication that he shall have a lien for the amount thereof.31
In some states, the statute provides for a pecuniary allowance to the widow of decedent. Occasionally, these statutes have been construed as making the land liable for the payment of such allowance in case of a deficiency of personalty, and in that case the amount thereof may be regarded as a lien on the land until other satisfaction of the claim.32 nell & Glessner Co. v. Minnesota & Dakota Elevator Co., 44 Minn. 390, 46 N. W. 773; Rawlings v. Hunt, 90 N. C. 270.
28. Wilson v. Taylor, 89 Ala. 368, 8 So. 149; Saloy v. Dragon, 37 La. Ann. 71; Buck v. Paine, 50 Miss. 648; Emerson v. Hed-rick, 42 Ark. 263. Compare Schilling v. Carter, 35 Minn. 287, 28 N. W. 658.
A statute giving a lien to one who bestows labor on personal property has been held not to give an agricultural laborer a lien on crops. McDearmid v. Foster, 14 Ore. 417, 12 Pac. 813. Contra, Hogue v. Sheriff, 1 Wash. T. 172.
29. Ante, Sec. 662.
30. Ante, Sec. 274.
31. Barker v. Owen, 93 N. C. 198; Whitcomb v. Provost, 102 Wis. 278, 78 N. W. 432.
32. See Detweiler's Appeal, 44 Pa. St. 243; Rector v. Reavill, 3 III. App. 232; Blakeman v. Blake-man, 64 Minn. 315, 67 N. W. 69; Allen v. Allen's Adm'r, 18 Ohio St. 234; 1 Woerner, Administration, 85.