CONNIE GUTIERREZ v. BOARD OF MANAGERS OF FLAGSHIP WHARF CONDOMINIUM.

100 Mass. App. Ct. 678
CourtMassachusetts Appeals Court
DecidedFebruary 2, 2022
StatusPublished
Cited by5 cases

This text of 100 Mass. App. Ct. 678 (CONNIE GUTIERREZ v. BOARD OF MANAGERS OF FLAGSHIP WHARF CONDOMINIUM.) is published on Counsel Stack Legal Research, covering Massachusetts Appeals Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
CONNIE GUTIERREZ v. BOARD OF MANAGERS OF FLAGSHIP WHARF CONDOMINIUM., 100 Mass. App. Ct. 678 (Mass. Ct. App. 2022).

Opinion

GUTIERREZ vs. FLAGSHIP WHARF CONDOMINIUM, 100 Mass. App. Ct. 678

CONNIE GUTIERREZ vs. BOARD OF MANAGERS OF FLAGSHIP WHARF CONDOMINIUM.

100 Mass. App. Ct. 678

October 8, 2021 - February 2, 2022

Court Below: Superior Court, Suffolk County

Present: Massing, Lemire, & Hand, JJ.

Condominiums, By-laws, Management. Practice, Civil, Summary judgment, Declaratory proceeding. Moot Question. Contract, Construction of contract. Declaratory Relief.

In a civil action seeking declaratory relief in a challenge to the propriety of the procedures for an election for two open seats on a board of managers of a condominium association, the plaintiff bore the burden of proof as the party arguing irregularity or seeking to alter the status quo to another party's disadvantage. [682-683]

A claim premised on an underlying argument that was no longer pressed on appeal by the plaintiff in a civil action was moot, and accordingly, this court declined to address the issue. [683]

In a civil action seeking declaratory relief in a challenge to the propriety of the procedures for an election for two open seats on a board of managers (board) of a condominium association (association), this court concluded that, although the board's decision to allow unit owners to vote through an online process and in advance of the annual meeting was permitted under the association's bylaws and was within the board's authority [683-687], the plaintiff was entitled to a judgment declaring that both a requirement that proxy designations be made before the commencement of the meeting without the opportunity to revoke them before the election and the direction of proxy designations to someone other than the clerk did not comply with the requirements of the bylaws [687-688].


CIVIL ACTION commenced in the Superior Court Department on July 2, 2019.

The case was heard by Susan E. Sullivan, J., on motions for summary judgment.

Dawn D. McDonald for the plaintiff.

Douglas W. Salvesen for the defendant.


HAND, J. The plaintiff is a residential unit owner in the Flagship Wharf Condominium (condominium). After failing in her 2019 bid for a seat on the board of managers (board) of the condominium association (association), she sued the board alleging that

Page 679

its 2019 change in election procedures violated the terms of the association's bylaws (bylaws). The plaintiff filed a complaint in the Superior Court, seeking declarations that (1) she had a right under both the bylaws and the Massachusetts Condominium Act, G. L. c. 183A, § 10 (c), to review certain election documents, including the individual ballots cast in the 2019 election; (2) "the election [was] void as electronic voting is not permitted under the [b]oard's by-laws"; and (3) "even if electronic voting [were] permissible, the election was not carried out according to the terms of the by-laws." [Note 1] The defendant counterclaimed, seeking declaratory judgment that the 2019 election "was in conformity with the By-Law and custom and practice of the association." On the parties' cross motions for summary judgment, the judge ruled against the plaintiff and in favor of the defendant on all claims. [Note 2] The judge did not explicitly declare the parties' rights on the issues identified in the plaintiff's complaint.

Reviewing the issues de novo, see Dorchester Mut. Ins. Co. v. Krusell, 485 Mass. 431, 435 (2020), we conclude that because the plaintiff's challenge to the board's refusal to provide her with its records of the 2019 election is moot, the portion of the judgment related to count I of the complaint must be vacated. We reverse in part the judgment for the board on count II of the complaint and direct the entry of a judgment declaring that (1) the use of electronic voting did not violate the condominium's bylaws by permitting unit owners to vote remotely and in advance of the annual meeting and (2) the board violated the bylaws in the 2019 election by (a) directing proxy designations to someone other than the clerk and (b) limiting unit owners' ability to revoke their proxies before the commencement of the annual meeting. The judgment is otherwise affirmed.

Background. The following facts are undisputed. At all relevant times, the condominium included 201 residential units and two commercial units in the Charlestown Navy Yard. The condominium was managed by the board, and its governing documents included the bylaws.

Page 680

The seven board members were elected by the unit owners for staggered two-year terms. [Note 3] The terms of two of the four residential members of the board expired each year. Pursuant to article 3, section 3.7, of the bylaws, in electing the residential board members, the residential unit owners voted using a weighted system based on each unit owner's percentage interest in the condominium's common elements. In addition to authorizing the board to perform a nonexclusive list of managerial responsibilities, the bylaws, at article 2, section 2.2(q), empowered the board to do "[a]nything and everything else necessary and proper for the sound management of the [c]ondominium and the [p]roperty." This discretionary authority included, as the parties agree, running the annual meetings and conducting the elections of the board members.

Prior to 2019, unit owners voted using paper "Proxy/Ballot" forms. Unit owners were entitled to vote whether they chose to attend the annual meeting or not. If a unit owner attended the meeting, he or she used the proxy/ballot form to indicate their choice of candidates, and then submitted the form while at the meeting. If a unit owner chose not to attend the meeting, then he or she completed the proxy/ballot form by (1) identifying the person authorized to act as proxy on either a general or directed basis, [Note 4] and (2) if using a directed proxy, specifying the candidates for whom the proxy vote could be cast.

Starting with the 2019 election, the board decided to use electronic balloting and an online voting tool in place of the paper ballots. Under this system, the board provided each unit owner with a link to an electronic ballot for his or her unit. A unit owner could complete the electronic ballot from a personal computer, computer tablet, or "smart phone," or could vote using a computer tablet made available in the condominium building's lobby. The electronic ballots provided unit owners an opportunity to vote for two of four candidates for the two open seats on the board. Unit owners were still able to vote through a general proxy; the board directed proxy designations to the property manager and set a deadline of noon on the day of the annual

Page 681

meeting for revocation of any existing proxy designation. [Note 5] The electronic ballots were made available to unit owners one week before the April 16, 2019, annual meeting. Although unit owners retained the right to vote in person at that annual meeting, they could, and in many cases did, cast their electronic ballots in advance of the meeting itself. [Note 6]

On April 9, 2019, the plaintiff requested that the board amend the bylaws to address the electronic voting system procedures. The board did not do so, the meeting was conducted as scheduled on April 16, 2019, and the board election was completed electronically. The plaintiff was not elected.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Cite This Page — Counsel Stack

Bluebook (online)
100 Mass. App. Ct. 678, Counsel Stack Legal Research, https://law.counselstack.com/opinion/connie-gutierrez-v-board-of-managers-of-flagship-wharf-condominium-massappct-2022.