Bald Head Island Ltd., LLC v. Vill. of Bald Head Island

CourtCourt of Appeals of North Carolina
DecidedAugust 6, 2025
Docket24-937
StatusUnpublished

This text of Bald Head Island Ltd., LLC v. Vill. of Bald Head Island (Bald Head Island Ltd., LLC v. Vill. of Bald Head Island) is published on Counsel Stack Legal Research, covering Court of Appeals of North Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bald Head Island Ltd., LLC v. Vill. of Bald Head Island, (N.C. Ct. App. 2025).

Opinion

An unpublished opinion of the North Carolina Court of Appeals does not constitute controlling legal authority. Citation is disfavored, but may be permitted in accordance with the provisions of Rule 30(e)(3) of the North Carolina Rules of Appellate Procedure.

IN THE COURT OF APPEALS OF NORTH CAROLINA

No. COA24-937

Filed 6 August 2025

Brunswick County, No. 23 CVS 98

BALD HEAD ISLAND LIMITED, LLC and BALD HEAD ISLAND TRANSPORTATION, INC., Plaintiffs,

v.

VILLAGE OF BALD HEAD ISLAND, Defendant.

Appeal by Defendant from order entered 14 March 2024 by Judge Jason C.

Disbrow in Brunswick County Superior Court. Heard in the Court of Appeals 8 April

2025.

Fox Rothschild LLP, by Kip D. Nelson, M. Gray Styers, Jr., and Bradley M. Risinger, and Murchison, Taylor & Gibson PLLC, by Michael Murchison and Andrew K. McVey, for Plaintiffs-Appellees.

Brooks, Pierce, McLendon, Humphrey & Leonard, L.L.P., by Andrew L. Rodenbough, Gary S. Parsons, and James C. Adams, II, for Defendant- Appellant.

GRIFFIN, Judge.

Defendant appeals from the trial court’s order granting Plaintiffs’ motion for

summary judgment on Plaintiffs’ claim for declaratory judgment seeking invalidation

of a Right of First Refusal (“ROFR”) to purchase infrastructure on Bald Head Island. BALD HEAD ISLAND LTD., LLC. V. VILL. OF BALD HEAD ISLAND

Opinion of the Court

Defendant argues the trial court erred by: (1) concluding the ROFR is unenforceable

because of the failure of a condition precedent; (2) concluding Defendant could not

enforce the ROFR because Plaintiffs provided notice to Defendant of their intent to

sell the assets as required by the ROFR; and (3) failing to hold Plaintiffs’ claim for

declaratory judgment was time-barred. We hold the trial court properly determined

the ROFR is void and unenforceable because of the failure of a condition precedent

and Plaintiffs’ claim was not time-barred. We do not reach the remaining issue

involving performance of the ROFR.

I. Factual and Procedural Background

Plaintiffs Bald Head Island Limited and its subsidiary, Bald Head Island

Transportation, are closely held corporations started by the late George Mitchell in

the 1980s. The corporations own and operate much of the infrastructure on Bald

Head Island. This includes the Ferry Operation and associated Parking Operation,

which provide the only means for large-scale public access to the island; the Tram

Operation to transport individual patrons around the island as it is mostly a vehicle-

free community; and the Barge Operation, which serves to transport goods to and

from the island (collectively “the assets”). Defendant Village of Bald Head Island is

the municipal corporation on the island.

In August 1999, the parties executed the ROFR to provide Defendant with an

opportunity to purchase the assets if Plaintiffs ever decided to sell them. Section 7 of

the ROFR states “This agreement shall become effective only upon approval by the

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North Carolina Utilities Commission.” Both parties concede neither sought Utilities

Commission approval of the ROFR, but both dispute who was responsible for

obtaining it.

After Mr. Mitchell’s passing in 2013, Plaintiffs began contemplating selling the

assets as part of administering Mr. Mitchell’s estate. In March 2017, the parties met

to discuss the transfer of the assets to a newly formed, multi-jurisdictional body, but

the deal fell through before the assets were transferred. Defendant recommitted

itself to purchasing the assets thereafter. On 13 January 2022, Defendant’s mayor

sent Plaintiffs a letter asserting its alleged rights under the ROFR. However, on 31

May 2022, Plaintiffs and SharpVue, a private equity firm in Raleigh, announced they

had executed an agreement to transfer the assets.

On 6 September 2022, Plaintiff Bald Head Island Limited delivered a copy of

the Asset Purchase Agreement between itself and SharpVue to Defendant in an

attempt to satisfy the notice requirement of the ROFR. The letter qualified the offer

with Plaintiffs’ position that the ROFR is void and unenforceable. Later that month,

Defendant requested additional information about the acquisition by SharpVue.

Specifically, Defendant requested SharpVue’s offer and appraisals, reports, and

studies on the assets and related properties contemplated by the Asset Purchase

Agreement. Plaintiffs refused to provide the additional information because of its

proprietary nature but did offer to allow Defendant access to the facilities for due

diligence and inspection purposes.

-3- BALD HEAD ISLAND LTD., LLC. V. VILL. OF BALD HEAD ISLAND

However, while the acquisition was processing, the parties engaged in

tangential litigation surrounding the Utilities Commission’s jurisdiction over the

assets and their transfer. In February 2022, Defendant initiated an action before the

Utilities Commission in which Defendant “requested that the [Utilities] Commission

investigate and determine the public utility status of [Plaintiff Bald Head Island

Limited] and its Barge and Parking Operations.” State ex rel. Util. Comm’n v. Bald

Head Island Transp., Inc., 296 N.C. App. 199, 204, 908 S.E.2d 851, 855 (2024) (“Bald

Head I”). Defendant also requested the Utilities Commission order the Parking and

Barge Operations are subject to the Utilities Commission’s authority and regulations

as an essential component of the Ferry System and as a common carrier service,

respectively. Id. The Utilities Commission entered an order on 30 December 2022

“determining that [Plaintiff Bald Head Island Limited’s] Parking and Barge

Operations are subject to its regulatory authority and cannot be sold without prior

[Utilities Commission] approval.” Id. at 204–05, 908 S.E.2d at 856. We affirmed the

Utilities Commission’s order subjecting the Parking Operations to its jurisdiction and

authority but reversed the portion of the order including the Barge Operations as

well. Id. at 224–25, 908 S.E.2d at 867.

Contemporaneously with the proceedings in Bald Head I, SharpVue “filed an

application with the Utilities Commission seeking approval to purchase the Ferry

Operation.” In re Bald Head Island Transp., Inc., 296 N.C. App. 554, WL 4821602 at

*1 (2024) (“Bald Head II”). We dismissed Defendant’s contention that the Utilities

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Commission “inappropriately approved the sale of the Barge Operation[,]” because of

our previous decision in Bald Head I, but upheld the Utilities Commission’s order

approving the sale of the Ferry and Parking Operations by Plaintiffs to SharpVue.

Id. at **2–3.

On 19 January 2023, Plaintiffs initiated this action by filing a complaint in

Brunswick County Superior Court seeking declaratory judgment that the ROFR is

not effective and Defendant forfeited its rights under the ROFR. Plaintiffs also

sought to quiet title to the assets. On 21 March 2023, Defendant answered Plaintiffs’

complaint and asserted counterclaims for declaratory judgment that Plaintiffs failed

to fulfill their obligations under the ROFR. Three days later, Defendant filed a notice

of lis pendens for various real property holdings related to the assets. Plaintiffs later

amended their complaint to add additional claims for slander of title and tortious

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