Bowa Estates Limited v. Association of Apartment Owners of Wailea Point Village

CourtDistrict Court, D. Hawaii
DecidedApril 22, 2025
Docket1:23-cv-00582
StatusUnknown

This text of Bowa Estates Limited v. Association of Apartment Owners of Wailea Point Village (Bowa Estates Limited v. Association of Apartment Owners of Wailea Point Village) is published on Counsel Stack Legal Research, covering District Court, D. Hawaii primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bowa Estates Limited v. Association of Apartment Owners of Wailea Point Village, (D. Haw. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF HAWAI‘I

BOWA ESTATES LIMITED, et al., Civil No. 23-00582 MWJS-RT

Plaintiffs, ORDER GRANTING IN PART AND RESERVING RULING IN PART ON vs. DEFENDANT’S MOTION FOR SUMMARY JUDGMENT ON ASSOCIATION OF APARTMENT DEFENDANT’S COUNTERCLAIM, OWNERS OF WAILEA POINT VILLAGE, DENYING IN PART AND RESERVING et al., RULING IN PART ON PLAINTIFFS’ MOTION FOR SUMMARY JUDGMENT Defendants. ON DEFENDANT’S COUNTERCLAIM, DENYING PLAINTIFFS’ REQUEST FOR A RULE 56(D) CONTINUANCE, AND DIRECTING SUPPLEMENTAL BRIEFING

INTRODUCTION This suit challenges the validity of an amendment made to the governing rules, or Declaration, of the Association of Apartment Owners of Wailea Point Village in Maui. Before the Amendment, owners who bought into the Association had agreed to 30-day minimum lease restrictions—that is, they agreed not to rent out their apartments for periods shorter than 30 days. In 2022, some of the apartment owners voted to adopt the Amendment, which purported to change the minimum rental period to a substantially longer period of one year, or 365 days. Not all the owners agreed to the change, however. Those who voted against it sued the Association and its Board members, asserting that the Amendment was not approved by the required number of owners.

The case is now before the Court on cross-motions for summary judgment on the Association’s counterclaim for a declaratory judgment. The principal question presented at this stage is a narrow one: whether the Amendment required the approval

of all the owners. For the reasons explained below, the Court concludes that it did not. On the current record, however, it is not clear whether the Association has met its burden to further show that the Amendment is valid and that the Association is entitled

to an order requiring specific performance. The Court therefore ORDERS the parties to submit supplemental briefing addressing those issues, as detailed below. Accordingly, the Court GRANTS IN PART and RESERVES RULING IN PART on the Association’s Motion for Summary Judgment on its Counterclaim, and DENIES

IN PART and RESERVES RULING IN PART on Plaintiffs’ Motion for Summary Judgment on the Association’s Counterclaim. For the reasons explained below, the Court also DENIES Plaintiffs’ request for a continuance under Federal Rule of Civil

Procedure 56(d). BACKGROUND A. Factual Background

1. The Declaration and the Amendment The condominium complex at issue, Wailea Point Village, is located in Wailea on the island of Maui. It encompasses three types of units: residential apartments, car

garage apartments, and boat garage apartments. ECF No. 60, at PageID.242 (Def.’s Concise Statement of Facts (CSF) ¶ 3). Plaintiffs in this case each own apartments in the complex and are members of its governing Association.

The Association’s role and rules are defined by the Declaration, which is a contract between the Association and property owners who buy into it. See ECF No. 60- 3. The Declaration lays out, among other things, various terms the owners agreed to be bound by in exchange for the Association’s services and common elements. Under

Section 7 of the Declaration, for example, which is titled “Purposes of and Restrictions on the Use of the Buildings, Individual Apartments and Common Elements,” the Declaration defines the purposes of the different types of apartments and the

restrictions on their use: The residential apartments may only be used as “residential dwellings.” Id. at PageID.262 (some capitalizations omitted). The car and boat garages, on the other hand, may be used as parking areas for motor vehicles and boats, among other things, but may not be used as dwellings. Id. In addition, Section 7 gives the

Association “the power to enact resolutions, rules and regulations . . . reasonably restricting and regulating the use of the apartments,” so long as they are “consistent with the terms” of the Declaration. Id. To that end, the Declaration establishes that the

owners have an “absolute right to lease” their apartments. Id. at PageID.263. But from the beginning, that right was expressly limited: the original Declaration provided that “no apartment shall be leased or rented by any apartment owner for transient purposes,

which is defined as a lease or rental for a period less than thirty (30) consecutive days.” Id. (emphasis added) (footnote omitted). In July 2022, the Association’s Board sent out consent forms to owners regarding

the Amendment. ECF No. 60-6, at PageID.355 (Consent Form); ECF No. 60-2, at PageID.250 (Ass’n Bd. President Valerie Hunter Decl. ¶ 6). The Amendment would change the definition of “transient purposes” in Section 7 of the Declaration: if approved, it would prohibit owners from leasing out their apartments for periods of

less than 365 days—a full year—rather than the existing 30-day minimum rental period. ECF No. 60-7, at PageID.356 (Amend.).1 2. The Consent Standards Contained in Sections 10 and 21.C of the Declaration

The Declaration contains two separate sections that address the process by which owners can amend it.

1 From Plaintiffs’ view, this move was part of a broader effort by the Board to limit taxes on the properties; it would allow the Board to seek a change of the condominium complex’s zoning from “hotel” to “apartment.” See ECF No. 63, at PageID.396. The central provision here is Section 10 of the Declaration, which broadly states in its first paragraph that “except as otherwise provided herein . . . this

Declaration . . . may be amended by either the affirmative vote or written consent of apartment owners owning apartments to which are appurtenant not less than sixty- seven percent (67%) of the common interest.” ECF No. 60-3, at PageID.268. Section 10

says that such an amendment “shall be effective only upon the filing in the Office of the Assistant Registrar of the Land Court of the State of Hawai‘i of an instrument setting forth such amendment and vote duly executed by such owners.” Id.

Section 10 goes on, however, to require the “consent of all apartment owners” for a limited set of amendments to the Declaration: amendments that “effect[] a change in the fundamental purposes of or restrictions on the use of any apartment or the common elements.” Id. at PageID.269. That provision, known as the “unanimity clause,” is

central to Plaintiffs’ suit. The second pertinent section of the Declaration, which lays out a separate approval threshold based on 67 percent of the owners, is Section 21.C. That section

provides: “Notwithstanding anything to the contrary in the Project governing documents, including but not limited to the Declaration, . . . Amendments to the Declaration . . . shall require approval of 67% of the owners.” Id. at PageID.274. 3. The Amendment Receives the Consent of the Owners of 70 Percent of the Common Interest

In the distributed consent forms, the Board took the position that the Amendment to the minimum rental period could be approved with the consent of the owners of 67 percent of the common interest under a voting standard set forth in Section 10 of the Declaration. See ECF No. 60-6, at PageID.355. According to the Association, when it received the consent forms back from the owners, that threshold

was met. ECF No. 60-2, at PageID.250 (Hunter Decl. ¶ 10) (stating that “[b]y October 18, 2022, written consent forms marked ‘approved’ had been received by more than 70% of all ownership interest in the AOAO”). And so on October 18, 2022, the Amendment was recorded in the State of Hawai‘i Office of the Assistant Registrar Land Court

System. Id. (¶ 9); ECF No. 60-9. The Amendment itself, however, did not state that it had been approved by owners of at least 67 percent of the common interest, as Section 10 of the Declaration

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