August 2011
In This Issue:
Owner Can Sue Neighbors Over Installation of Wood Floors
Board Chosen for Removal Must Have Chance to Speak
Injunction a Remedy for Governing Document Violations
Disabled Resident’s Behavior Violates Declaration
Rejection of Settlement Agreement is Breach of Contract
Landscaper Not Liable for Unit Owner’s Injuries
Rules Violation Fines Limited by State Statute
Directors May Seek Restitution for Litigation Expenses
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Owner Can Sue Neighbors Over Installation of Wood Floors

Baldwin v. Village Walk Condominium, Inc., No. FSTCV085007925S, Conn. Super. Ct., Nov. 19, 2010

Architectural Control: Owners who replaced the carpet in their condominium unit with hardwood floors are liable for allegations of negligent infliction of emotional distress, breach of contract and unjust enrichment due to the increased noise level in the unit directly beneath theirs.

Robin Baldwin purchased unit 41 in Village Walk Condominium. Carole Mills and James Scott owned unit 43 directly above Baldwin and installed hardwood floors in their unit. Baldwin sued Mills and Scott—as well as the current owner, Jane Powell, Village Walk Condominium, Inc. (association), and Imagineers, LLC (the property manager)—asserting 42 claims relating to the installation of the wood floors in unit 43. Baldwin alleged the wood floors created intolerable noise levels in her unit and interfered with her efforts to sell the property. The defendants filed a joint motion to strike all but 10 of her claims. The court dismissed 26 claims but allowed the allegations of negligent infliction of emotional distress, unjust enrichment and breach of contract to stand.

Baldwin alleged that the association, Imagineers and Powell negligently inflicted her with emotional distress. In another count of her complaint, she stated similar claims against Mills and Scott. In their motion to strike Baldwin’s claim, the defendants claimed that she did not allege that it was reasonable for them to foresee that installing the wood floor in unit 43 would result in intolerable noise in Baldwin’s unit, causing her great emotional distress.

To prevail on a negligent infliction of emotional distress claim, a party must plead and prove that the defendant’s conduct: (1) created an unreasonable risk of causing emotional distress; (2) the distress was foreseeable; (3) the emotional distress was severe enough that it might result in illness or bodily harm; and (4) the offending conduct was the cause of the plaintiff’s distress.

Baldwin pleaded that the association, the property manager and Powell “should have realized that their conduct involved an unreasonable risk of causing emotional distress, and that distress, if it were caused, might result in illness or bodily injury” and they “knew or should have known that emotional distress was the likely result of their acts.” However, these conclusions were unsupported by facts. Baldwin failed to provide any facts that the association, the property manager or Powell could have foreseen that their conduct might cause Baldwin emotional distress. The court, therefore, granted their motion to strike the claim.

Baldwin then alleged that by removing the carpeting from unit 43 and installing wood floors, Mills and Scott intentionally inflicted her with emotional distress. The court found that Mills and Scott knew, or should have known, that replacing the carpeting in their unit with wood floors was likely to create undue burdensome noise in Baldwin’s unit. Therefore, the court denied their motion to strike this claim.

Baldwin also alleged that the association and property manager were unjustly enriched because they profited at her expense by “failing to perform their duty to inspect and abate the nuisance.” She also claimed the association and property manager were unjustly enriched by the work she performed to soundproof her unit, which included a permanent improvement to the floor/ceiling assembly—a part of the condominium’s common area. As to Mills and Scott, Baldwin claimed the installation of the wood floors constituted an unjust enrichment because they were able to sell their unit at a significantly higher price than she could sell her unit for because the wood floors were considered a valuable improvement, whereas her unit was now uninhabitable and unmarketable because of the noise produced by the wood floors in unit 41.

Unjust enrichment applies whenever justice requires that compensation be given for property or services rendered under a contract, and no remedy is available under the contact. The doctrine is based on the principle that one should not be permitted to unjustly enrich himself at the expense of another.

The court held that Baldwin adequately alleged unjust enrichment claims against Mills and Scott and denied their motion to strike. However, the court could not find any basis to support Baldwin’s claim against the association or the property manager.

Baldwin argued that Mills and Scott breached material terms of the condominium declaration. Mills and Scott moved to strike these counts, asserting that Baldwin lacked standing to bring the action because the declaration was merely a contract between the association and individual unit owners. However, Connecticut’s Common Interest Ownership Act provides that, “A declarant, association, unit owner or any other person subject to this chapter may bring an action to enforce a right granted or obligation imposed by this chapter, the declaration or the bylaws.” The court found that because the declaration was a contract and Connecticut statutes grant unit owners standing to pursue claims arising out of the declaration, Baldwin’s breach of contract action was a proper vehicle for enforcing those statutory rights. Moreover, the court noted that the Connecticut appeals court implicitly approved actions between unit owners for violations of condominium declarations. Accordingly, the court denied Mills’ and Scott’s motion to strike this claim.

©2011 Community Associations Institute. All rights reserved. Reproduction and redistribution by CAI members or nonmembers are strictly prohibited.

Board Chosen for Removal Must Have Chance to Speak

Board of Managers of Academy Twins Condominium v. Hernandez, No. 112410/10, N.Y. Supr. Ct., Dec. 16, 2010

Association Operations/Powers of the Association: Although condominium unit owners elected a new president to its board of managers, the election was invalid because the removed president was not given an opportunity to be heard at the meeting.

Academy Twins Condominium is located in Kings County, N.Y., and is governed by the nine-member board of managers (board).

The condominium bylaws provide that board members and officers may be removed by a majority vote of the unit owners at any regular or special meeting, with or without cause, after which replacements may be elected. However, a board member or officer selected for removal is entitled to be heard at the meeting. A majority of members constitute a quorum.

In December 2009, board members were elected for 2010. On Jan. 18, 2010, the newly elected board met and elected Ines Hernandez as president. The board also voted that day in favor of e-mail voting, which Hernandez voted against.

In February, via e-mail vote, the board removed Hernandez as president and elected the board’s vice president, David Shargani, to take her place. Hernandez remained a member of the board. On Feb. 12, 2010, Hernandez and another board member advanced a resolution, whereby a majority of the unit owners signed a petition to remove and replace Shargani and several of the board members. The resolution passed on Feb. 19, 2010. No one on the board was removed at that time; however, the board split its loyalties between Hernandez and Shargani.  

On July 29, 2010, Shargani, claiming the presidency, brought an action against Hernandez and her supporters on the board to invalidate her petition to remove him and the other supporters on the board members. However, his complaint was dismissed on the grounds that the e-mail election that allegedly gave him the presidency was unauthorized by the association’s bylaws, and the New York Condominium Act accorded only the president or treasurer the capacity to sue on behalf of a condominium. The court ruled Hernandez was still president. Shargani remained on the board.

Between July 30, 2010, and Aug. 10, 2010, Hernandez sent e-mail notices to the board, giving notice of a regular meeting to be held on Aug. 11, 2010. All five members of the board, including Shargani, were present at the meeting. At the meeting, Hernandez circulated a petition to the unit owners that called for a special meeting to remove Shargani and his supporters from the board. Also during that meeting, Shargani was allegedly elected president.

On Sept. 1, 2010, Hernandez, holding herself out as the board’s president, sent notice to the unit owners of a special meeting which would be held on Sept. 21 2010, to remove Shargani and his supporters on the board. Hernandez noted that 28 percent of the unit owners had signed the petition she had circulated during the Aug. 11 meeting.

Before the meeting to remove Shargani and his supporters could take place, though, Shargani sued Hernandez on Sept. 18, 2010, seeking an order to declare that he was president of the condominium board. According to the board, Shargani had allegedly been elected at the Aug. 11 meeting and had the right to a one-year term. Hernandez filed a cross-claim the beginning of October.

To support his cause of action, Shargani argued that Hernandez’s petition to remove him and his supporters from the board was invalid because the signatures were not notarized or witnessed. Shargani also asserted that only he, as president, could call a special meeting.

Hernandez responded that Shargani lacked the capacity to sue on behalf of the board because he was not president or treasurer. She asserted that she was elected on Jan. 18, 2010, and Shargani was not elected at the Aug. 11 meeting because the resignation of a board member had left less than a quorum at the meeting, and the e-mail notice of the meeting was unauthorized by the bylaws.

The Condominium Act (act) governs condominium operations (if so acknowledged in the bylaws) and requires that the bylaws provide procedures for nomination and election of a board of managers. The act also requires the bylaws to designate the number of members, with at least one-third of the members serving greater than one-year terms.

Although the Academy Twins bylaws did not provide that notices of board meetings could be conveyed by e-mail, the court observed that, nonetheless, each board member was aware of the Aug. 11 meeting date; that the condominium’s board meetings had previously been noticed by e-mail; and that Hernandez was present at the meeting when Shargani was elected. In the court’s opinion, the e-mail notice did not undermine the objectives of the bylaws or the Condominium Act.

The court further found that even though Shargani announced the resignation of a member of the quorum present at the meeting, it was clear that the resignation would take effect pending a confirmation letter. Absent the letter, the board member never effectively resigned. Consequently, the court deemed there was a quorum present at the meeting, the election was valid and Shargani was duly elected president.

Because at least 25 percent of the unit owners signed Hernandez’s petition, Shargani, as president, was required to call the special meeting, even if it was not in his interest to do so. However, Shargani and his supporters on the board were not given an opportunity to be heard before their removal, which constituted a violation of the bylaws and the Condominium Act.

The court concluded that the Sept. 21 meeting, which there is no record of having ever taken place, was invalid and, therefore, the board remained the same as it was following the Aug. 11 meeting. The court granted Shargani’s petition, declaring him president of the board effective as of Aug. 11, 2010. Hernandez’s cross-motion was denied in its entirety.

The court admonished the parties for not showing any effort by them and others to cooperate or serve in the best interests of the condominium. Notwithstanding any resolution reached by the court, both parties were told to resolve future differences through good faith negotiation and a great deal of compromise.

©2011 Community Associations Institute. All rights reserved. Reproduction and redistribution by CAI members or nonmembers are strictly prohibited. 

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Injunction a Remedy for Governing Document Violations

Briarwinds Condominium Association, Inc. v. Rigsby, 51 So.3d 532 (Fla. App. Ct. 2010)

Covenants Enforcement: A Florida appeals court reversed a finding that a condominium association failed sufficiently to demonstrate irreparable injury in an action to evict a resident who violated the condominium documents.

Marcene Rigsby owned a unit in Briarwinds Condominium that she rented to Denny Wood. After numerous complaints by residents and the police, culminating with a petition signed by 88 people to evict Wood, Briarwinds Condominium Association, Inc., (association) sued Rigsby and Wood, seeking to evict Wood from the condominium, alleging numerous rules violations, including harassing women and children, disruptive conduct, threatening neighbors and guests, and using vulgar language.

Several years after the lawsuit was filed, Rigsby and Wood filed motions for judgment on the pleadings regarding the association’s action to evict Wood. The court granted the motions, holding that the association failed to effectively state its claim for eviction. The court dismissed the claim and denied the association’s motion for a rehearing. The association appealed.

The appeals court’s review of the complaint and its attachments demonstrated that the claim for eviction was sufficiently stated. The court explained that a motion for judgment on the pleadings should only be granted if a party is entitled to judgment as a matter of law. In this case, the court was not convinced that Rigsby and Wood were entitled to judgment as a matter of law, and, further, there were still unresolved factual questions.

On appeal, Rigsby and Wood argued that the association failed to allege irreparable injury, a necessary component of claims for injunctive relief. However, the association sought Wood’s eviction based on Rigsby’s and Wood’s violations of the Florida Condominium Act (act). The statute provides that in an action asserting a violation of the statute, the alleged violation is itself a harm for which the act authorizes injunctive relief. The court concluded that the association had adequately demonstrated irreparable injury by alleging that Wood violated the condominium rules. 

The appeals court reversed the trial court’s judgment and remanded the case for further proceedings.

©2011 Community Associations Institute. All rights reserved. Reproduction and redistribution by CAI members or nonmembers are strictly prohibited.

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Disabled Resident’s Behavior Violates Declaration

Connors v. Lake Dexter Woods Homeowners Association, Inc., No. 2D09-5382, Fla. App. Ct., Dec. 29, 2010

Covenants Enforcement: The Florida appeals court reluctantly affirmed an injunction in favor of a homeowners association to prohibit a developmentally disabled resident’s abusive conduct.

Daniel Connors, Jr. lives in Dexter Woods subdivision in Polk County, Fla. Until a few years ago, he lived with his father. His father developed a friendship with Delbert Watson, who is developmentally disabled, and brought him into the home. After his father died, Connors became Watson’s guardian advocate.

Watson has an “angry” personality and has used “vulgar, vile, abusive and rude language” loudly around the neighborhood. Although he was never violent toward anyone in the neighborhood, he did threaten to hurt people. He drove his car in a threatening manner toward pedestrians in the neighborhood and was abusive to prospective homebuyers and guests. The subdivision residents were frightened of him and viewed him as a “tragedy waiting to happen.”

Lake Dexter Woods Homeowners Association, Inc., (association) sued Watson to establish that his conduct violated the declaration of covenants, conditions and restrictions that governed the neighborhood.

The trial court found that Watson’s long-standing conduct constituted a nuisance. The court prohibited Watson from engaging in his abusive conduct and required Connors, as Watson’s guardian advocate, to take all reasonable steps to prevent Watson from violating the ruling.

Watson had not been declared legally incapacitated, and his exact mental status was not established in the trial record. However, the circuit court declared him a “person with a developmental disability” pursuant to Florida’s public health statute and appointed Connors as his guardian advocate.

The order appointing Connors as guardian advocate was introduced at trial. It delegates to Connors the authority to exercise all Watson’s legal rights and gives Connors the powers of care, custody and control of Watson. The trial court determined that Watson’s disability was “no excuse for allowing the nuisance or violation of the declaration to continue unabated.”

The appeals court concluded that the trial court’s findings were supported by competent substantial evidence but observed that the evidence concerning Watson’s status could be far more complete. The extent to which Watson could consistently control his own behavior was not well established. Also, it was not clear what exactly Connors could do to fulfill his obligation to “exercise all reasonable care to prevent . . .” Watson from violating the trial court’s order.

Notwithstanding its doubt whether an injunction could effectively address the problem, the appeals court had no authority to vacate the order. It observed that, as a result, Connors had incurred $47,000 in attorney’s fees unsuccessfully defending his disabled friend and would have another judgment entered against him for the fees associated with the appeal.

©2011 Community Associations Institute. All rights reserved. Reproduction and redistribution by CAI members or nonmembers are strictly prohibited.

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Rejection of Settlement Agreement is Breach of Contract

Herring v. Heron Lakes Estates Owners Association, Inc. No. 14-09-00772-CV, Texas App. Ct., Jan. 4, 2011

Covenants Enforcement/Architectural Control: A Texas appeals court upheld a finding that a homeowners association was entitled to judgment for breach of contract against residents who rejected the terms of a settlement agreement for violations of the restrictive covenants.

Theodore Herring, Jr. owns a lot in Heron Lakes Estates in Houston, Texas. The Heron Lake Estates Homeowners Association sued Herring for not complying with the association’s declaration of covenants, conditions and restrictions, including refusal to pay assessments and failure to follow the association’s architectural guidelines. Herring countersued, seeking a declaration that he was not bound by the declaration.

Before the hearing, the parties settled the lawsuit. At the hearing, the court directed the parties to put their agreement on the record. Each side dictated a number of terms the parties had allegedly agreed upon, one of which was that Herring would comply with the declaration once an agreement was reached.

Herring later refused to comply with the declaration or other terms of the settlement agreement. The association amended its lawsuit to include a breach of contract claim and moved for summary judgment. The trial court ruled in the association’s favor, ordering Herring to sign the declaration, pay the association $700 in assessments and move the wrought iron fence on his property. The court then held a bench trial on the remaining issues. At trial, the court awarded the association $71,804 in attorney’s fees and rendered a take-nothing judgment on Herring’s counterclaim. The court ordered Herring to complete construction of his house and remove a chain link fence he had installed. Herring appealed.

Contract law governs agreements that are made in open court. Parties may enter into a binding settlement agreement even if they contemplate executing a more formal document later. Reducing stipulations to writing does not affect the nature and effect of the stipulations dictated in open court.  Herring argued no contract was formed because the parties did not intend to enter into a presently binding agreement but had only an “agreement to agree.” Herring further argued that his consent was necessary for the court to render a judgment enforcing the settlement agreement.

The transcript of the hearing reflected the following statement: “The agreement that we’ve reached today is that . . . my client will ratify the declaration, and that ratification will be done when we reach a settlement on this . . . which is in the next week or so, and that . . . assessments under those CCRs will begin, prospective only, when we enter into the settlement agreement going forward. They will not be retrospective.”

Herring argued that the phrases “when we reach a settlement” and “when we enter into the settlement agreement” indicated that the parties did not intend to enter into the settlement agreement at the hearing. However, the court found that it was clear and unambiguous from the context of the settlement hearing that the word “when,” rather than “if,” was used to express a duration of time rather than a condition precedent to the contract’s formation. The court found no ambiguity in the transcript that Herring agreed to comply with the declaration and assessments would begin prospectively. The settlement agreement addressed every issue raised in the association’s original petition. The court concluded that the parties intended to be presently bound by the agreement, and the numerous terms dictated in the record were not conditioned on any future negotiations or executing formal settlement documents.

Herring also argued that the association was precluded from a grant of attorney’s fees because it waived its right to recover under an express term of the settlement agreement, which stated, “There will be no attorneys’ fees awarded on either side.”

Pursuant to the Texas rules of civil practice, a party may recover attorney’s fees on a breach of contract claim “in addition to the amount of a valid claim and costs.” Here the trial court awarded $700 in maintenance assessments. Accordingly, the association was statutorily entitled to recover attorney’s fees. To have waived this right in the settlement agreement, the waiver must have specifically precluded the statutory claim. The court found that the settlement agreement’s provision did not specifically preclude a statutory award of attorney’s fees for breaching the settlement agreement itself. Rather, the parties agreed that they would bear their own fees incurred in the negotiation and settlement, not that the association waived attorney’s fees incurred to enforce the settlement agreement. Accordingly, the court overruled Herring’s argument.

Having overruled both of Herring’s issues on appeal, the court affirmed the trial court’s judgment.

©2011 Community Associations Institute. All rights reserved. Reproduction and redistribution by CAI members or nonmembers are strictly prohibited.

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Landscaper Not Liable for Unit Owner’s Injuries

Lubell v. Stonegate at Ardsley Home Owners Association, Inc., No. 2010-00880, N.Y. Supr. Ct., App. Div., Dec. 28, 2010

Risks and Liabilities: A New York appeals court upheld a trial court’s finding that a contractor that performed snow removal services for a condominium association could not be held liable for injuries sustained by a unit owner who slipped on black ice in the street.

Terry Lubell slipped and fell on black ice outside her unit in Stonegate at Ardsley condominium complex. She sued Stonegate at Ardsley Homeowners Association, Inc. (association), its managing agent and Westchester Hills Landscaping, Inc., which performed snow removal services for the association.

Lubell alleged that the black ice that caused her fall resulted from melting and re-freezing snow that was plowed onto a nearby lawn two days before her accident. The association filed a cross claim against Westchester for common-law and contractual indemnification (restitution for loss, damages or injuries) and for contributing to Lubell’s accident. Westchester moved to dismiss Lubell’s complaint and all cross claims asserted against it.  

The trial court granted Westchester’s motion in its entirety and denied the association’s cross motion to convert its cross claims into a third-party action. Lubell and the association appealed.

The appeals court affirmed the trial court’s decision, holding that a limited contractual commitment to provide snow removal services did not render a contractor liable for personal injuries sustained by third parties. Westchester established its entitlement to judgment by demonstrating that Lubell was not a party to its snow-removal contract with the association. Since there was no evidence that Westchester either owed a duty of reasonable care to Lubell or a duty of reasonable care independent of its contractual obligations to the association, the court found that the trial court properly dismissed the claims.

©2011 Community Associations Institute. All rights reserved. Reproduction and redistribution by CAI members or nonmembers are strictly prohibited.

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Rules Violation Fines Limited by State Statute

Tahiti Beach Homeowners Association, Inc. v. Pfeffer, No. 3D10-786, Fla. App. Ct., Jan. 5, 2011

Covenants Enforcement: The Florida appeals court affirmed a finding that statutes relating to remedies operate retrospectively, and the statutory limitation on a homeowners association’s fines for rule violations applied even though the association’s rule was adopted before the statute was adopted.

Tahiti Beach Homeowners Association, Inc., (association) had repeatedly fined Wendell Pfeffer for allegedly violating the association’s Homesite Construction Rule. After Pfeffer refused to pay and amassed $285,000 in fines, the association sued Pfeffer to foreclose the lien. The Homestead Construction rule requires property owners to complete construction or landscaping projects within 24 months or be fined $10,000 per month until the work is completed. The trial court ruled in Pfeffer’s favor, finding that the rule did not meet the requirements of the Florida’s Homeowners Association statute. The association appealed.

The issue on appeal was whether the statute, enacted in 1995, applied to the association’s rule, adopted in 1993 or 1994, with respect to Pfeffer’s alleged violations that occurred from 2007–2009.

The court determined that the limitation on fines and the requirements for prior notice and a hearing, which are imposed by the statute, are unquestionably procedural and remedial in nature. Further, the statutes relating to remedies operate retrospectively in the sense that all pending proceedings, including matters on appeal, are determined under the law in effect at the time of the decision rather than the law in effect when the suit arises. Because remedial and procedural issues were addressed in this case rather than vested substantive rights, this record did not present a constitutional issue, as raised by the association. Thus, the court concluded that the trial court correctly granted summary judgment in Pfeffer’s favor.

©2011 Community Associations Institute. All rights reserved. Reproduction and redistribution by CAI members or nonmembers are strictly prohibited.

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Directors May Seek Restitution for Litigation Expenses

Wendt v. La Costa Beach Resort Condominium Association, Inc., No. SC09-1914, Fla. Supr. Ct., June 9, 2011

Risks and Liabilities/Attorney’s Fees: The Florida Supreme Court reversed the dismissal of an action for indemnity (restitution for loss, damages or injuries) filed by the directors of a condominium association to recover expenses incurred in the association’s suit against them for breach of fiduciary duty.

Donald Wendt, Kenneth Wendt and Clarke Warne were directors of La Costa Beach Club Resort Condominium Association, Inc. (association), a timeshare condominium in Pompano Beach, Fla. In 2003, the association sued the directors for breach of fiduciary duty. After the verdict was ruled in the association’s favor, the directors moved for a new trial and brought a separate indemnification action against the association for expenses incurred in defending the lawsuit. The trial court dismissed the action, and the directors appealed.

The appeals court affirmed the trial court’s ruling, holding that the directors could not state a cause of action under the case’s circumstances. The court deemed that indemnity is only available to someone who performs a duty that should have been performed by the other party and that party is entirely at fault.

In this case, the directors did not claim that they discharged a duty that the association should have discharged, that they incurred liability because of the association’s wrongful acts or that they were held liable to any third party. In the court’s opinion, the directors sought to use the state’s corporations statute as a vehicle to recover their attorney’s fees and costs if they prevailed in the association’s suit for breach of fiduciary duty. The appeals court upheld the trial court’s finding that because there was no statutory right to indemnification in actions between corporations and their own directors, the directors failed to state a cause of action. The directors appealed.

The Supreme Court defined indemnity as the “duty to make good any loss, damage or liability incurred by another” or “[t]he right of an injured party to claim reimbursement for its loss, damage or liability. . .” Florida’s corporate indemnification statute states the conditions under which directors are entitled to indemnification. That statute provides that corporations are allowed to indemnify persons who are a party to the corporation’s proceeding to procure indemnification  because that person is or was a corporation’s director. The statute’s plain language does not prevent indemnification of directors when the underlying proceeding is between the corporation and its directors. The court found, furthermore, that the legislature set forth various restrictions on when indemnification is proper, but none of the restrictions excludes all lawsuits between a corporation and its directors.

Therefore, the court held that the statute authorized the directors to seek indemnification from the association for actions brought against them for breach of fiduciary duty. The court expressly did not consider the merits of whether indemnification applied under the facts of this case. The court reversed the trial and appeals courts and remanded the case for further proceedings.

In a dissenting opinion, Judge J. Quince held, like the appeals court, that indemnification is required only when one party discharges an obligation that should have been discharged by the other party, and the trial court correctly dismissed the directors’ attempt to “engraft that interpretation” upon the statute.

©2011 Community Associations Institute. All rights reserved. Reproduction and redistribution by CAI members or nonmembers are strictly prohibited.

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