October 2017
In This Issue:
Recent Cases in Community Association Law
Easement Holders Must Share Easement Maintenance Costs
Poorly Planned Condominium Boundaries Lead to Dispute
Covenants Expire When Association Fails to Record Correctly
Federal Foreclosure Bar Preempts Nevada HOA Foreclosure Law
Association Liable for Increased Repair Costs Due to Payment Delay
Custom Home Violates Subdivision Restrictions
Court Allows Converting Golf Course to Residential Use
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Recent Cases in Community Association Law

Law Reporter provides a brief review of key court decisions throughout the U.S. each month. These reviews give the reader an idea of the types of legal issues community associations face and how the courts rule on them. Case reviews are illustrations only and should not be applied to other situations. For further information, full court rulings can usually be found online by copying the case citation into your web browser. In addition, the College of Community Association Lawyers prepares a case law update annually. Summaries of these cases along with their references, case numbers, dates, and other data are available online.

Easement Holders Must Share Easement Maintenance Costs

Tanglewood Property Owners’ Association, Inc. v. Isenhour, 803 S.E. 2d 453 (N.C. Ct. App. Aug. 1, 2017)

Documents: The North Carolina Court of Appeals held that a lot owner who was not an association member was obligated to pay a share of the association’s costs to maintain certain easements, but the owner was not obligated to subsidize the developer’s lots since it had no agreement with the developer.

For about 20 years, Frank and Linda Register had owned two lots in the Tanglewood West phase of the Tanglewood subdivision in Brunswick County, N.C. Tanglewood Property Owners’ Association, Inc. (association) was a voluntary homeowner association that owned the subdivision common areas. The Registers were not members of the association.

Some common areas were reserved for association members only, but all lot owners had the right to use the subdivision streets, ditches, waterway access, and boat ramp (collectively, the easement areas). From 1985 to 2013, the association paid to maintain all easements areas and common areas.

In 2013, the association determined that all non-developer lot owners should pay an equal share of the easement area maintenance costs, and it determined that each lot’s share was $128. Maintenance costs for association members were factored into their assessments. However, the association billed all non-members. The Registers refused to pay.

In 2014, the association sued the Registers, Brandon Isenhour, and other owners who did not pay to determine the parties’ rights and obligations in the easement areas. The association asserted that the Registers owed $281 (an assessment for each lot plus a $25 late fee).

The Registers admitted that the Tanglewood West plat granted them certain easements, but they denied any responsibility to maintain those easements. They also asserted that the association charged its members less than it charged nonmembers, although the members received more benefits. The Registers asserted that they did not use the easement areas except the roads necessary to access their property, and they were willing to contribute to road maintenance. The Registers complained that they should not be required to join a voluntary association, and they should not be forced to maintain property for others.

The Tanglewood West plat referenced in the Registers’ deed showed a boat ramp, parking lot, and a private street (the West easement areas). The trial court ruled that the plat did not grant easements to the Registers, but they did have an easement by necessity over the two private roads necessary to access their lots. The trial court held that the Registers were obligated to pay reasonable, pro rata maintenance costs for the two roads. The association appealed.

To create an easement by plat, the plat must sufficiently identify the easement area. The general rule for maintaining an easement is that, in the absence of an agreement to the contrary, all easement holders share the costs.

The appeals court found that the Tanglewood West plat sufficiently depicted the West easement areas. Thus, the Registers held easements in the West easement areas, although there was nothing that granted them easements in all easement areas. The appeals court determined that such easements ran with the land and added value to the Registers’ lots. Accordingly, the easements conferred a benefit on the Registers’ lots, even if they did not currently use them all.

The appeals court noted that the proper method to calculate the Registers’ maintenance costs was to divide the maintenance costs for the West easement areas by the total number of lots in Tanglewood West, including the developer lots. The appeals court noted that, although the developer would not pay assessments for its lots, they should be included in the equation. There was no agreement obligating non-association members to contribute to the developer's share of the costs.

Accordingly, the trial court’s judgment was reversed, and the case was remanded for further proceedings.

©2017 Community Associations Institute. All rights reserved. Reproduction and redistribution in any form is strictly prohibited.

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Poorly Planned Condominium Boundaries Lead to Dispute

Madden v. Scott, No. 1-16-2149 (Ill. App. Ct. Aug. 11, 2017)

Documents: The Appellate Court of Illinois upheld an easement over a portion of a condominium unit in favor of the adjoining unit where such portion provided access from the outside to the adjoining unit’s front door.

In 1986, Joseph and Kathleen Madden purchased Unit 60 in a six-unit condominium in Cook County, Ill. Unit 60 was attached to Unit 50, and both were fronted by a vestibule composed mostly of windows and French doors.

Most of the vestibule was located within Unit 50’s boundaries, including the French doors, which opened to the outside; the remaining vestibule was within Unit 60’s boundaries. Thus, to reach Unit 60’s front door from the outside, the Maddens had to cross through Unit 50’s boundaries. Unit 60 had two other exterior doors – one to the garage and one to the patio. However, the mailbox was outside the vestibule front door, and that was where packages arrived and visitors entered.

Neither the Maddens nor their guests had trouble entering through the vestibule until Thomas and Sylvie Scott moved in next door. The Scotts began renting Unit 50 in 1995 and purchased the unit in 2006.

The vestibule door had never been locked since each unit had a locking front door inside the vestibule. However, immediately after their purchase, the Scotts informed the Maddens that they owned most of the vestibule, but they did not say the Scotts could not use it. In 2009, the Scotts obtained a permit to wall off their portion of the vestibule, which would block access to Unit 60’s front door. They posted the permit in the vestibule, and the Maddens immediately filed suit.

The Maddens claimed an easement over the vestibule for Unit 60’s benefit. They asserted three possible theories for the easement: an express easement under the condominium declaration, an implied easement of necessity for ingress and egress, or a prescriptive easement based on the time they had been using the vestibule. The Scotts counterclaimed, seeking a declaration that they owned the vestibule area containing the exterior door.

The trial court determined that both an implied and a prescriptive easement existed for Unit 60’s benefit. The trial court barred the Scotts from interfering with the Maddens’ passage through the vestibule, ordered them to remove their personal property from the vestibule, and ordered that the vestibule door remain unlocked unless both owners had keys. The trial court’s order specifically stated it ran with the land and bound the present and future owners of Units 50 and 60.

The Scotts appealed, arguing that there could be no implied easement because access through the vestibule was not essential since Unit 60 had other exterior doors. The appeals court disagreed, holding that the vestibule need not be the only access; it was sufficient if it would be highly convenient for enjoying the property. The appeals court determined that vestibule access was necessary to access Unit 60’s front door, highly convenient to retrieve packages and mail and to allow access for guests.

The Scotts argued that the Maddens did not acquire a prescriptive easement since they could not establish adverse, uninterrupted, exclusive, and continuous use for 20 years. The appeals court held that “exclusive” in this context did not mean that no one else used the area; rather, it meant that the use right did not depend upon another’s use right. The trial court found that the Maddens’ or their guests’ using the vestibule to access Unit 60’s front door had been adverse, uninterrupted, exclusive, and continuous for 20 years.

The appeals court found no evidence that that the Maddens’ vestibule use was interrupted until 2011, when their daughter found the vestibule door locked from the outside, long after the 20-year prescriptive period had run. There was also no evidence that the Maddens used the vestibule with the express permission of Unit 50’s owner, so their use was adverse.

The Scotts argued that there was no precedent for granting an easement over a condominium unit’s interior living space. While the vestibule was located within Unit 50’s boundaries, the appeals court noted that it was outside the unit’s living space. Like Unit 60, Unit 50 had a front door in the vestibule, so there was no interference with Unit 50’s living space. Therefore, the appeals court saw no reason to deviate from traditional easement law analysis simply because the property at issue was a condominium.

Accordingly, the trial court’s judgment was affirmed.

©2017 Community Associations Institute. All rights reserved. Reproduction and redistribution in any form is strictly prohibited.

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Covenants Expire When Association Fails to Record Correctly

DiDonato v. Pueblo Del Sol Property Owners Association, No. 2 CA-CV 2016-0219 (Ariz. Ct. App. July 12, 2017)

Documents: The Court of Appeals of Arizona held that an association’s covenants had expired because it failed to record owner consent to extend them.

Pueblo Del Sol Property Owners Association (association) governed a community in Cochise County, Ariz. The community’s 1972 covenants, conditions, and restrictions (covenants) were set to expire on December 31, 2015, unless a document extending them was signed by owners representing at least 55 percent of the land area, notarized, and recorded.

In November 2015, the association notified the owners that the covenants were set to expire in December and asked the owners to consent to extend the covenants to 2030 by signing a form.  Owners representing 62.07 percent of the total community acreage returned signed consent forms.

On December 28, 2015, the association’s president and secretary executed a notice stating that the covenants were extended (extension notice), which was recorded the following day. The actual consent forms were neither notarized nor recorded.

In January 2016, owners Louis DiDonato, Dale and Nancy Chidester, and Dennis and Carol Kaunzner (collectively, plaintiffs) filed suit against the association, seeking a declaratory judgment (judicial determination of the parties’ legal rights) that the covenants had expired on December 31st. Determining that the extension notice was insufficient to extend the covenants, the trial court granted summary judgment (judgment without a trial based on undisputed facts) to the plaintiffs.

The association appealed, arguing that the recorded extension notice was sufficient since it was executed and acknowledged by the association and supported by the requisite number of owner consents in the association’s files. The appeals court ruled that there was no ambiguity in the requirements to extend the covenants—they clearly provided that an extension document had to be executed by the owners and notarized. No provision contemplated that the association officers could simply swear that the required consents had been obtained.

The association asserted that substantial compliance was sufficient, viewing the consent requirements as mere administrative technicalities that were not integral to the extension notice. The appeals court did not agree that substantial compliance was the proper measure of performance.

The cardinal principle in interpreting restrictive covenants is to give effect to the original parties’ intent. The appeals court determined that the failure to record signed and notarized owner consents was a material failure to comply with the covenants’ requirements.

The association argued that the appeals court should follow the Restatement (Third) of Property, which allows a court to excuse an association from complying with requirements for member consent to covenant amendments. However, before covenant requirements can be excused, the court must find they unreasonably interfere with managing common property, administering the covenants, or carrying out required functions.

The court must also determine that compliance is not necessary to protect the legitimate interests of owners and their mortgagees. The association provided no such evidence, but rather admitted that obtaining notarized owner consents was incredibly difficult and time consuming. The appeals court found nothing in the Restatement that excused compliance requirements merely because they were difficult and time consuming.

Rather, the Restatement’s comments indicated that the relaxation provisions should be applied sparingly and only when covenant requirements were poorly drafted or impaired the association’s ability to operate. The appeals court ruled that the association’s failure to comply with the covenants’ plain terms meant that the covenants expired.

Accordingly, the trial court’s judgment was affirmed.

©2017 Community Associations Institute. All rights reserved. Reproduction and redistribution in any form is strictly prohibited.

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Federal Foreclosure Bar Preempts Nevada HOA Foreclosure Law

Berezovsky v. Moniz, 869 F.3d 923 (9th Cir. Aug. 25, 2017)

Federal Law and Legislation: The Ninth Circuit Court of Appeals held that the Federal Foreclosure Bar prevented Freddie Mac’s unrecorded mortgage interest from being extinguished when a Nevada association foreclosed its super-priority lien.

In 2007, Gregory and Idell Moniz purchased a home in Las Vegas, Nev. The community was governed by Garden Terrace Homeowners Association (association). The Monizes took out a $220,000 loan secured by a deed of trust (mortgage) that named Mortgage Electronic Registration Systems, Inc. (MERS) as the lender’s beneficiary and loan servicing agent.

The Federal Home Loan Mortgage Corporation (Freddie Mac) purchased the Monizes’ promissory note in 2007 but did not record a mortgage assignment. Freddie Mac is under the conservatorship of the Federal Housing Finance Agency (FHFA), so FHFA temporarily owns and controls Freddie Mac’s assets. In 2011, MERS assigned its interest in the mortgage to Bank of America, N.A. (BANA), who recorded the assignment.

In 2011, the Monizes became delinquent in association assessments, and the association recorded a lien against their home. The association foreclosed its lien in 2013. Alex Berezovsky purchased the home at the foreclosure sale for $10,500.

Berezovsky then sued everyone who had a recorded prospective interest in the property, including the Monizes and BANA, seeking a declaration that he held title free and clear of any liens. Berezovsky asserted that, when the association foreclosed its super-priority lien, it stripped the mortgage and all other liens from the property.

Freddie Mac and FHFA intervened and moved for summary judgment (judgment without a trial based on undisputed facts), asserting that the property remained subject to the mortgage. They argued that the Federal Foreclosure Bar (act) preempted Nevada law, which meant that Freddie Mac’s interest could not be extinguished without its consent. The trial court ruled in Freddie Mac’s favor, and Berezovsky appealed.

The act prohibits foreclosing, attaching, or selling FHFA property without its consent. Berezovsky argued that the act did not apply because it only protects against state and local tax liens, not private liens like the association’s. He also asserted that Freddie Mac implied that it consented to the foreclosure when it did nothing to stop it.

The appeals court held that the act clearly applied to any case in which the FHFA serves as conservator. It also found that the act’s property protection section does not mention taxes or limit foreclosure methods. Moreover, the act does not require FHFA to resist foreclosure actively to be protected. Rather, FHFA’s property is protected unless FHFA affirmatively relinquishes such protection.

Berezovsky also disputed that the act preempted Nevada law. The U.S. Constitution’s Supremacy Clause provides that, when federal and state law conflict, federal law prevails. Preemption occurs when it’s impossible to comply with both state and federal law or when state law conflicts with congressional objectives.

Since real estate foreclosure is traditionally regulated by the states, Nevada may presume its super-priority lien will not be preempted, unless Congress’ intention to supersede state law is clear and manifest.

The appeals court held that Congress did not use sufficiently definite language to create an express preemption. However, it did find that the act clearly intended to preempt state lien law. While the act prohibits foreclosing FHFA property without its consent, foreclosing a super-priority association lien automatically extinguishes FHFA’s property without its consent. Thus, the appeals court found Nevada law conflicted with Congress’ clear goal to protect FHFA’s assets and held that the act superseded Nevada law.

Berezovsky further argued that Freddie Mac held no recorded interest in the mortgage. Nevada law requires a lien to be recorded to be enforceable, but it does not mandate that it identify the lien’s owner. The Nevada Supreme Court has held that, if the beneficiary named in a recorded mortgage is someone other than the promissory note owner, that doesn’t void either instrument. Nevada law recognizes that the note owner remains a secured creditor with a property interest, even if the recorded mortgage names only the note owner’s agent.

Thus, Freddie Mac’s security interest remained valid and enforceable, and the act protected that interest from being extinguished. Accordingly, the trial court’s judgment was affirmed.

©2017 Community Associations Institute. All rights reserved. Reproduction and redistribution in any form is strictly prohibited.

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Association Liable for Increased Repair Costs Due to Payment Delay

AMI Association Management, Inc. v. Sprecher, No. 01-15-00791-CV (Tex. App. Aug. 17, 2017)

State and Local Legislation and Regulations: The Texas Court of Appeals held that a condominium association that required owners to repair their own units following hurricane damage was liable for an unreasonable delay in turning over insurance proceeds to the owners.

David and Leslie Sprecher owned three units in the Parc Condominiums in Houston, Tex. Parc Condominium Association (association) governed the project.

In 2008, Hurricane Ike caused substantial damage to the building. The association’s management company, AMI Association Management, Inc. (AMI), filed claims with the association’s insurer. The association’s contractor began the repairs, but the work was shoddy. After the contractor caused further damage to their units, the Sprechers refused to allow the contractor to enter their units.

Realizing the contractor’s performance was unsatisfactory, the association asked all owners to obtain their own repair estimates. In March 2011, the Sprechers obtained a $97,000 estimate for their units and sought to oversee the work for their units themselves. In August 2011, AMI received a check from the insurer for that amount, but it did not pay the Sprechers for another two years. In the meantime, the units were uninhabitable, and the repair costs had increased by $48,000.

The Sprechers sued the association and AMI for the increased repair costs. A jury found that the association and AMI had unreasonably delayed paying the Sprechers and awarded them $48,000 plus attorney’s fees, but it declined to award them damages for lost rental income.

The association and AMI appealed, asserting that the Texas Uniform Condominium Act (act) provided that unit owners are not entitled to payments until after the property has been completely repaired. Furthermore, the condominium declaration provided that insurance proceeds be paid to the association and held in trust for the owners, as their respective interests may appear.

The appeals court explained that the phrase “as their respective interests may appear” was a loss-payable clause commonly used in insurance policies. It means that the loss payee (in this case, the unit owner) stands in the insured’s shoes and has the same rights as the insured. Thus, once they were instructed to obtain their own repairs, the Sprechers had the same rights to the insurance proceeds as the association.

The appeals court determined that the act did not refer to all insurance payments, but only to surplus proceeds that might remain after all repairs were completed. In that case, the insurance trustee has discharged the repair obligation and could distribute surplus proceeds to the unit owners without condition. The appeals court stated that the act did not prevent the association from paying owners for repairs; rather, it prohibited paying out funds unconditionally before the repairs were complete.

AMI complained that it was only the association’s agent and should not be held independently liable. The Sprechers argued that they were third-party beneficiaries of the management contract. A third party may recover under a contract made by other parties only if the contract was made for the third party’s benefit. Under the management agreement, AMI accepted the association’s obligations to the owners, so the trial court did not err in rendering judgment against both the association and AMI.

However, the appeals court found the evidence insufficient to support the $48,000 damage award. The association pointed out that some of the increased repair costs were for asbestos abatement that was not covered by insurance. Thus, the payment delay was not related to those costs. Since the jury could not determine the correct damages caused by the payment delay, the appeals court reversed the trial court’s judgment and remanded the case for a new trial to determine damages.

©2017 Community Associations Institute. All rights reserved. Reproduction and redistribution in any form is strictly prohibited.

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Custom Home Violates Subdivision Restrictions

Thiel v. Goyings, No. 333000 (Mich. Ct. App. Aug. 8, 2017)

Use Restrictions: The Michigan Court of Appeals held that a custom home constructed partially of factory-built modules violated the subdivision restrictions.

David and Helen Goyings owned a lot in the Timber Ridge Bay subdivision of Allegan County, Mich. The Goyings contracted with a custom homebuilder to design and construct a home. The home was composed of three modules that were manufactured by Ritz-Craft Custom Homes at its facility in Jonesville, Mich. The modules were transported to the lot by truck, and a crane placed them on the lot. Then, the homebuilder connected the modules and constructed other portions of the home.

The Goyings’ neighbors, Matthew and Nikole Thiel and William and Marcia Traywick (collectively, plaintiffs) sued the Goyings, asserting that the home violated the Timber Ridge Bay declaration of restrictions, covenants, and conditions (declaration). Three different declaration sections prohibited, in various ways, modular, mobile, manufactured, and prefabricated homes in the subdivision. The declaration also required that residences be stick-built (a wood-frame house constructed entirely or largely on the site it will occupy when finished, rather than in a factory) on site and prohibited moving a residence onto a subdivision lot from outside.

The Goyings responded that their home was entirely stick-built—just not entirely stick-built on site. They claimed most of the home was built on site, and only a small part was built offsite. The Goyings asserted that, while the home did use prefabricated components, none of the modules constituted a residence as it was delivered to the site. Rather, the components had to be assembled, and additional construction was required to turn the components into a habitable home. For example, electrical, duct work, plumbing, and a roof had to be added.

The Goyings argued that the restrictions were vague and did not clarify how much construction could be prefabricated for the entire home to be prohibited by the declaration. Many other subdivision homes were being built with prefabricated components, such as cabinets, trusses, and foundations. The Goyings asserted that, if the other prefabricated components were allowed, theirs must also be allowed.

The trial court determined that the aesthetics, quality, and value of the Goyings’ home was comparable to the other subdivision homes. It further found it unlikely that anyone would know the home had been built elsewhere. The trial court held that the home met all the standards and specifications of a stick-built home. As such, the trial court held that the home did not violate the declaration. The plaintiffs appealed.

The appeals court held that, although the declaration did not define “modular,” the term was not ambiguous and should have been given its ordinary and generally understood or popular meaning, without technical refinement. The dictionary defined modular as composed of standardized units or sections for easy construction or flexible arrangement, such as a modular home.

The appeals court held that the Goyings’ home was a modular home in clear violation of the unambiguous restriction. Accordingly, the only solution was to grant the relief requested and order the home to be removed. Further, the Goyings’ claim that a modular home was just as good as an on-site, stick-built home was not relevant where the restriction was unambiguous. The value and aesthetics were not at issue. The trial court was not free to decide whether it agreed with the restriction; it was required to enforce the declaration as written.

Accordingly, the trial court’s judgment was reversed in part, and the case was remanded for further proceedings.

©2017 Community Associations Institute. All rights reserved. Reproduction and redistribution in any form is strictly prohibited.

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Court Allows Converting Golf Course to Residential Use

Friends of Crooked Creek, L.L.C. v. C.C. Partners, Inc., 802 S.E. 2d 908 (N.C. Ct. App. July 18, 2017)

Use Restrictions: The North Carolina Court of Appeals declined to impose a restriction on golf course property where no recorded document clearly indicated an intent to bind the property to golf course use only.

In 1992, C.C. Partners, Inc. (developer) began developing the Crooked Creek subdivision in Fuquay-Varina, N.C. The first two plats recorded reflected a golf-themed community with street names such as Tee Box Court and Shady Greens Drive and easements reserved for golf ball retrieval and golf course utilities and irrigation, but they did not show a golf course or dedicate any property for golf course use. The developer recorded a declaration of covenants, conditions, and restrictions (declaration) that referenced a golf course.

In 1994, the developer sold 24 lots and five unsubdivided tracts to MacGregor Development Company (MacGregor). In 1995, the developer recorded a plat entitled “Map of Crooked Creek Golf Course and Subdivision” (1995 plat) that showed a golf course, driving range, clubhouse, and other golf features drawn with dashed lines. Five tracts labeled A, B, C, D, and F were drawn with solid, bold lines.

The deed conveying the five tracts to MacGregor referenced the 1995 plat. Neither the deed nor the purchase contract restricted the land retained by the developer. MacGregor subdivided the tracts by recorded plats that showed lots next to property labeled “Crooked Creek Golf Course.” The developer completed the golf course construction after the MacGregor sale was completed.

While MacGregor was solely responsible for marketing the lots, MacGregor and the developer worked together to sell lots and golf club memberships. For example, a home sales center was located in the golf clubhouse, MacGregor’s brochures referenced a golf course and golf-course home sites, and the developer offered a discounted golf membership to Crooked Creek owners.

In 2002, the developer transferred about one-half of the golf course property to a related company, Crooked Creek Golf Land, LLC (CCGL). The golf club experienced hardships during the recession and never fully recovered. The developer announced its intention to close the golf course and convert the property to residential lots.

Friends of Crooked Creek, LLC (FOCC) was formed by 78 Crooked Creek lot owners to preserve the beauty, value, and livability of the subdivision. In June 2015, FOCC and three other owners (collectively, plaintiffs) sued the developer and CCGL (collectively, defendants), seeking a determination that the declaration restricted the golf course property to golf and related uses. The plaintiffs also sought to prevent the golf course from closing and converting the property into residential lots.

The trial court declined to intervene in the golf course closure. The club permanently closed in July 2015, and most of the club assets were sold. The trial court granted summary judgment (judgment without a trial based on undisputed facts) in the defendants’ favor.

The plaintiffs appealed, arguing that the declaration promised that the golf course property would be used only for golf. The appeals court disagreed.

The declaration stated that a golf course was contemplated for property located in or near the subdivision. It warned of the risks of living near a golf course and reserved easements for golfers. The appeals court declined to interpret such provisions as a burden on the golf course property.

Restrictions will not be implied on property not specifically described or rights granted to persons for whom benefits are not specifically reserved. The appeals court held that the golf course references did not describe specific uses or describe property to be bound.

While the declaration exempted the golf course from assessments, it also stated the exemption would not apply if the property was converted to residential purposes. The appeals court held that this clearly indicated the golf course could be converted to residential use. Furthermore, the declaration did not designate the developer’s retained property as community common area.

The plaintiffs argued that the marketing materials and the 1995 plat implied a restriction. For a restriction to be implied, the plat must clearly show the developer intended to restrict the land use for the benefit of lots shown on the plat. The 1995 plat did not clearly show an intent to restrict the golf course use and did not show lots, only unsubdivided tracts. Further, the developer did not sell lots by reference to the 1995 plat. None of the plaintiffs’ deeds referenced a plat recorded by either defendant, only plats recorded by other, unaffiliated parties.

While marketing materials can provide further evidence of a developer’s intent, the appeals court held that such materials are relevant only where there is a recorded instrument that clearly demonstrates the intent to encumber and restrict land use.

Accordingly, the trial court’s order was affirmed.

©2017 Community Associations Institute. All rights reserved. Reproduction and redistribution in any form is strictly prohibited.

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