Caruso Builder Belle Oak v. Sullivan

CourtCourt of Appeals of Maryland
DecidedJanuary 28, 2025
Docket2/24
StatusPublished

This text of Caruso Builder Belle Oak v. Sullivan (Caruso Builder Belle Oak v. Sullivan) is published on Counsel Stack Legal Research, covering Court of Appeals of Maryland primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Caruso Builder Belle Oak v. Sullivan, (Md. 2025).

Opinion

Caruso Builder Belle Oak, LLC v. Ronalda Sullivan, No. 2, September Term, 2024. Opinion by Eaves, J.

MD. CODE ANN., REAL PROPERTY § 14-117(a)(3)(i) – ACCRUAL OF CLAIMS

Section 14-117(a)(3)(i) of the Real Property Article (“RP”) of the Annotated Code of Maryland requires that contracts for the initial sale of real property located in Prince George’s County, where “there are deferred private water and sewer assessments recorded by a covenant or declaration deferring costs for water and sewer improvements for which the purchaser may be liable[,]” disclose to the purchaser eight pieces of information. A violation of that provision entitles an aggrieved purchaser to immediately pursue statutorily enumerated remedies under RP § 14-117(b)(2).

In this case, Caruso Builder Belle Oak, LLC (“Caruso”) entered into a contract with Ronalda Sullivan on July 17, 2015, for a qualifying piece of real property that was subject to RP § 14-117(a)(3)(i). Caruso provided a noncompliant disclosure on that date, and the parties settled on the contract on February 24, 2016. Ms. Sullivan filed a complaint against Caruso on February 22, 2019, seeking monetary penalties under RP § 14-117(b)(2)(i). The Supreme Court of Maryland held that a seller’s violation of RP § 14-117(a)(3)(i) gives rise to a cause of action because the aggrieved purchaser suffers an informational harm, and RP § 14-117(b)(2)(i)–(iii) provides corresponding remedies. Because Ms. Sullivan knew or should have known that, at the time of contract, Caruso’s disclosure was noncompliant, and because Ms. Sullivan had at least one remedy available to her, Maryland’s general, three-year statute of limitations began to run on July 17, 2015. Thus, her claim against Caruso was barred by the applicable statute of limitations. Circuit Court for Prince George’s County Case No. CAL19-06087 Argued: September 5, 2024

IN THE SUPREME COURT

OF MARYLAND

No. 2

September Term, 2024

CARUSO BUILDER BELLE OAK, LLC

v.

RONALDA SULLIVAN

Fader, C.J., Watts, Booth, Biran, Eaves, Wilner, Alan M., (Senior Justice, Specially Assigned), Hotten, Michele D., (Senior Justice, Specially Assigned),

JJ.

Opinion by Eaves, J.

Pursuant to the Maryland Uniform Electronic Legal Materials Act (§§ 10-1601 et seq. of the State Filed: January 28, 2025 Government Article) this document is authentic.

2025.01.28 12:33:23 -05'00' Gregory Hilton, Clerk I INTRODUCTION

Buying a home is a significant undertaking, and homebuyers want information

disclosed up front to make informed decisions about their ability to afford a home. This

case concerns water and sewer assessments—important information in the homebuying

process.

Pursuant to § 14-117(a)(3)(i) of the Real Property Article (“RP”) of the Annotated

Code of Maryland (2023 Repl. Vol.) (the “Disclosure Act”), a contract for the initial sale

of real property located in Prince George’s County, where “there are deferred private water

and sewer assessments . . . for which the purchaser may be liable[,]” must disclose eight

pieces of information to the purchaser. These deferred water and sewer assessments are

costs incurred by private companies that have assumed responsibility from a county

government “in the development processes of constructing infrastructure for water and

sewer lines.” 1

On July 17, 2015, Petitioner, Caruso Builder Belle Oak, LLC (“Caruso”), a

residential real estate builder, and Respondent, Ronalda Sullivan, a homebuyer, entered

into a contract for Ms. Sullivan to purchase a home in Prince George’s County. Along

with the contract, Caruso provided Ms. Sullivan with a disclosure for deferred water and

sewer assessments, and the parties went to settlement on the contract in February 2016.

1 Joseph N. Schaller & Shannon D. Sentman, Private Water and Sewer Assessment Companies, 39-Oct. Md. B.J. 36, 37 (2006). These deferred water and sewer assessments are secured “by recording an instrument among the land records of the applicable county . . . in the form of a declaration of deferred water and sewer charges[,]” which “establishes a lien that runs with the land to secure the assessments[.]” Id. Nearly three years after settlement, in February 2019, Ms. Sullivan filed a cause of action

against Caruso, 2 alleging that the required disclosure was noncompliant.

The parties agree that a cause of action for Caruso’s noncompliance is subject to

Maryland’s general, three-year statute of limitations, codified at § 5-101 of the Courts and

Judicial Proceedings Article (“CJP”) (2020 Repl. Vol.). We granted a writ of certiorari in

this case to determine when the three-year period of limitations begins for a cause of action

for a violation of the Disclosure Act. 3 Caruso argues that Ms. Sullivan’s claim accrued at

the time the parties entered into the contract for the sale of real property, while Ms. Sullivan

contends that her claim accrued on the date of settlement because that is the earliest date

for which she became liable for the deferred water and sewer charges. The answer

determines whether CJP § 5-101’s statute of limitations bars Ms. Sullivan’s claim for

Caruso’s noncompliance with the Disclosure Act. 4

We hold that Ms. Sullivan’s cause of action for Caruso’s Disclosure Act violation

accrued at the time the parties entered into the contract because that is the date on which

(1) the single element of Ms. Sullivan’s cause of action was complete and (2) Ms. Sullivan

knew or should have known of Caruso’s noncompliance, permitting her to maintain a

2 In her original complaint, Ms. Sullivan sued two entities: Caruso Builder Belle Oak, LLC, and Caruso Homes, Inc. The latter entity eventually was dismissed from the litigation because it was not a real party in interest, leaving only the former on appeal. 3 Caruso Builder Belle Oak, LLC v. Sullivan, 486 Md. 388 (2024). 4 At oral argument, counsel for Caruso conceded that a monetary figure it was required to disclose as one of the eight pieces of information was “incorrect.” Counsel stated that the incorrect figure formed the basis for the violation of the Disclosure Act alleged in Ms. Sullivan’s complaint. 2 successful action against Caruso. In so holding, we reverse the judgment of the Appellate

Court of Maryland and remand to that court with instructions to affirm the judgment of the

Circuit Court for Prince George’s County, which granted Caruso’s motion to dismiss for

failure to state a claim upon which relief could be granted.

II BACKGROUND

We begin with an overview of the pertinent provisions of RP § 14-117 before

addressing the factual background and procedural history.

A. Pertinent Provisions of RP § 14-117

The Disclosure Act requires, among other things, the initial seller of residential real

property located in Prince George’s County to make certain disclosures. The pertinent

provision states:

In Prince George’s County, a contract for the initial sale of residential real property for which there are deferred private water and sewer assessments recorded by a covenant or declaration deferring costs for water and sewer improvements for which the purchaser may be liable shall contain a disclosure that includes:

1. The existence of the deferred private water and sewer assessments;

2. The amount of the annual assessment;

3. The approximate number of payments remaining on the assessment;

4. The amount remaining on the assessment, including interest;

5.

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Caruso Builder Belle Oak v. Sullivan, Counsel Stack Legal Research, https://law.counselstack.com/opinion/caruso-builder-belle-oak-v-sullivan-md-2025.