Daniel C. Lavering v. University Village Owners Association

CourtCourt of Appeals of Virginia
DecidedMay 5, 2026
Docket1710242
StatusPublished

This text of Daniel C. Lavering v. University Village Owners Association (Daniel C. Lavering v. University Village Owners Association) is published on Counsel Stack Legal Research, covering Court of Appeals of Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Daniel C. Lavering v. University Village Owners Association, (Va. Ct. App. 2026).

Opinion

COURT OF APPEALS OF VIRGINIA

Record No. 1710-24-2

DANIEL C. LAVERING v. UNIVERSITY VILLAGE OWNERS ASSOCIATION

Present: Chief Judge Decker, Judges Malveaux and Duffan Argued at Richmond, Virginia Opinion Issued May 5, 2026

FROM THE CIRCUIT COURT OF ALBEMARLE COUNTY Cheryl V. Higgins, Judge

Kyle McNew (John B. Simpson; MartinWren, P.C.; MichieHamlett PLLC, on briefs), for appellant.

Marla J. Diaz (Claudia Lopez-Knapp; Whiteford, Taylor & Preston L.L.P., on brief), for appellee.

PUBLISHED OPINION BY JUDGE KEVIN M. DUFFAN

At issue in this case is whether a condominium may amend its condominium instruments

to extend the time limit for the expansion of new units with less than unanimity of the owners of

the existing units. We conclude that Code §§ 55.1-1916(C)(3) and -1934(B) allow such an

amendment to be accomplished through a two-thirds vote. Accordingly, we affirm the trial

court’s grant of summary judgment in favor of the University Village Owner’s Association. BACKGROUND

In 1991, University Village, Inc., established an expandable condominium1 in Albemarle

County by declaration made subject to the Virginia Condominium Act, Code §§ 55.1-1900

through -1995.2 As the declarant, University Village reserved the right to expand the

condominium at its discretion within seven years from the date of the declaration. If not

exercised, the option to expand would “in all respects expire and be of no further force and

effect.”

Initially, the condominium included 1 building with 46 units, referred to as “Phase I of

University Village.” Each unit included an “undivided interest in the Common Elements

appertaining to that unit.”3 The declaration stated that “the Percentage Interest assigned to each

Unit . . . shall change” if new units were added to the condominium. The declaration also stated

it could be amended by a “vote of at least 66-2/3% of the Unit Owners.”

Within 7 years of the declaration, University Village constructed a “Phase II” building

with 48 additional units. The seven-year expansion period provided by the declaration expired in

1998. In 2003, 94.3% of the condominium’s unit owners approved an amendment to the

declaration to expand the period in which University Village could submit “Phase III” to the

condominium regime. The proposal was to authorize a development company that was already

under contract to expand the condominium within three and a half years of the amendment.

1 An “expandable condominium” is “a condominium to which additional land may be added in accordance with the provisions of the declaration and” the Virginia Condominium Act. Code § 55.1-1900. 2 Code §§ 55.1-1990 through -1995 were repealed effective July 1, 2023. 3 “‘Common elements’ means all portions of the condominium other than the units.” Code § 55.1-1900. -2- Despite that amendment, no new units were constructed. Daniel Lavering purchased a

condominium unit in University Village in 2004.

Due to renewed talk about the proposed “Phase III” expansion, in October 2021

Lavering’s counsel sent a letter to the president of the University Village Owner’s Association’s

Board of Directors expressing the view that any expansion required unanimous consent of the

unit owners. Referring to the declaration and the 2003 amendment, the Association manager

responded that the declaration could be amended by consent of two-thirds of unit owners. In

January 2022, the Board adopted a policy resolution “to begin the process of amending the . . .

Declaration to allow for construction of Phase 3 units.” To that end, the Board “engage[d] the

services of [counsel] to draft a proposed declaration amendment to allow development of Phase 3

of the condominium” at an estimated cost of $5,000 to $7,000. At a June 2022 town meeting,

unit owners were told that “[p]resent thinking is that this summer could provide time to prepare

for a Fall vote of condo unit owners on Phase III” and that the vote would be whether to amend

the declaration to submit additional land to the condominium.

Lavering filed a declaratory judgment action against the Association in May 2022. As

relevant here, Lavering requested a declaratory judgment that the Association could not expand

the condominium without unanimity from the unit owners, alleging that “[t]he Association has

asserted and continues to assert that there can be expansion of the Condominium with only a 66

and 2/3 favorable vote by the Unit Owners.” The Association denied that allegation in its

answer. In April 2023, the Association moved for summary judgment, claiming, among other

arguments, that it could amend the declaration to extend the declarant expansion period by a

two-thirds vote of its unit owners. After a hearing, the circuit court granted the Association’s

motion.4 The circuit court found that University Village, Inc. was the declarant, not the

4 The Court also denied Lavering’s cross-motion for partial summary judgment. -3- Association. In the court’s view, the option to expand contained in the declaration was an option

to expand “made by the declarant and only by the declarant.” The circuit court then turned to

Code § 55.1-1916, finding that it limited the declarant’s ability to expand but not the

Association’s. As the circuit court explained, it was anticipated that the condominium would

“last for a significantly longer period than seven years or ten years” and it was “too narrow an

interpretation” of the statute to limit the expansion period. Consequently, the circuit court found

that the expansion period could be “extended by whatever entity is then, at that time, the

controlling entity of the additional property and that it can be extended by an amendment at any

time to the declaration as there is no time limit in the statute.” Finally, the circuit court found

that the amendment could be approved by two-thirds support of the unit owners. Lavering

moved for reconsideration, which the trial court denied.

Lavering also moved for sanctions, contending that the Association had acted in bad faith

by denying its two-thirds position in its answer and then taking that position in its motion for

summary judgment. Lavering claimed that the Association’s tactic resulted in unnecessary and

costly litigation and specifically asserted that he incurred at least $40,000 in unnecessary

attorney fees and costs during discovery because of the Association’s denials. Although finding

“questionable reasons” for the Association’s denials, ultimately the circuit court denied the

motion for sanctions, finding no bad faith because there is a difference between expanding the

condominium and extending the right to expand. The circuit court also found that the issues “did

not impact [Lavering’s] analysis of this case overall.”

The Association requested attorney fees of $126,756.97 as the prevailing party under

Code § 55.1-1915. The trial court awarded the Association $81,223 in attorney fees. Lavering

appeals.

-4- ANALYSIS

A. The Association’s Threshold Arguments

As an initial matter, the Association argues that Lavering’s lawsuit is premature because

the Association has not yet presented a proposal for expansion to the condominium’s unit

owners. “[T]he Declaratory Judgment Act provides a ‘procedural remedy for the unripe, but

legally viable, cause of action’” and “afford[s] ‘relief from the uncertainty and insecurity

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Daniel C. Lavering v. University Village Owners Association, Counsel Stack Legal Research, https://law.counselstack.com/opinion/daniel-c-lavering-v-university-village-owners-association-vactapp-2026.