Harrington v. Seaside Condominium Ass'n

CourtSuperior Court of Maine
DecidedNovember 7, 2014
DocketYORre-12-250
StatusUnpublished

This text of Harrington v. Seaside Condominium Ass'n (Harrington v. Seaside Condominium Ass'n) is published on Counsel Stack Legal Research, covering Superior Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Harrington v. Seaside Condominium Ass'n, (Me. Super. Ct. 2014).

Opinion

~a.

£ N T E RED NOV 1 8 Z014

STATE OF MAINE SUPERIOR COURT YORK, SS. DOCKET NO. ~-12-250 ~t:

ROBERT G. HARRINGTON and 30N- YDR- 11-07-14- BETH E. MCDERMOTT HARRINGTON,

Plaintiffs,

v. ORDER

SEASIDE CONDOMINIUM ASSOCIATION et al.,

Defendants.

I. Background

A. Procedural Posture

Plaintiffs Robert G. Harrington and Beth E. McDermott Harrington ("the

Harringtons") bring this suit against the Seaside Condominium Association ("Seaside" or

"the Association") and several of its officers, alleging they violated provisions of the

governing documents, improperly accounted for various fees assessed and assessed some

in a discriminatory manner, and that use of an easement by other units for utility access

damaged the Harringtons' unit. (Compl. 3.) The complaint further seeks injunctive relief

ordering Seaside to comply with the governing documents. Seaside answered,

counterclaimed for unpaid condominium fees, and moved to dismiss. Before the court is

Seaside's motion for summary judgment on its counterclaim.

1 B. Facts

The parties agree on the following facts. Seaside Condominium is a condo

complex in York, Maine. The Declaration of the Seaside Condominium Association is

recorded in the York County Registry of Deeds ("the Registry") at Book 4554, Page 198-

240. (Def. 's S.M.F. ~ 1.) The Harringtons purchased Unit #1 ("the Harrington Unit") on

March 18, 2008. (Def. 's S.M.F. ~ 3.) The Harrington Unit deed is recorded at Book

15377, Page 139 and references the Seaside Condominium Declaration. (Def.'s S.M.F. ~

4.) On March 22, 2012, Seaside filed a lien on the Harrington Unit for unpaid

assessments. (Def.'s S.M.F. ~ 6.) 1

Article 3, Section 3.3(c) of the Declaration, which governs maintenance

responsibilities states:

Water service to all Units will be included in the Common Expenses. Electric and propane gas service to units 4 through 9 will be charged as a Limited Common Expense to those six Units and such charges will be allocated equally among such Units. Electric service to Unit 1 through 3 and sewer, telephone and cable television service to all Units will be separately metered and each such unit owner shall be responsible for the cost of such services furnished to his Unit.

(Pl.'s S. Addt'l M. F.~ 22.) Article 5, § 5.2 governing common expenses states:

The liability of each Unit for the Common Expenses of the Condominium shall be the same percentage share as the Percentage Interest set forth on Exhibit B, and as such shall be determined by dividing the approximate square footage of each Unit as of the date of the Declaration (exclusive of Limited Common Elements) by the total square footage of all the Units (exclusive of Limited Common Elements) in the Condominium.

(Pl.'s Mem. Opp. Mot. Summ. J., Ex. A). Exhibit B sets forth that Unit 1, the Harrington

Unit, is approximately 2,018 square feet and therefore the percentage governing property

1 The parties dispute nearly every other material fact asserted by Seaside in support of its motion for summary judgment. Those facts related to the manner in which the assessments were calculated and administered, which the Harringtons assert was erroneously conducted. (Pl.'s Reply Def. 's S.M.F. ~~ 7-27.)

2 interest stake, voting power, and Common Expense liability (excluding Limited Common

2 Elements) is 38.7%. Id

II. Discussion

A. Summary Judgment Standard

Summary judgment is appropriate where there are no material facts in dispute and

the moving party is entitled to judgment as a matter oflaw. M.R. Civ. P. 56. "A material

fact is one having the potential to affect the outcome of the suit." Burdzel v. Sobus, 2000

ME 84, ,-r 6, 750 A.2d 573. Where there is sufficient evidence to support competing

versions of material facts, the outcome must be decided by the factfinder at trial. Id

B. Validity of the Fees Assessed to the Harrington Unit

The issue in this case is whether Seaside has properly allocated expenses in

assessments, specifically with regards to utility costs. In the Harringtons' view, starting in

2011, an amendmene was made to the Declaration that improperly allocated utility costs

based on certain percentages, rather than separately metering the units. (Pl.'s S. Addt'l M.

F. ,-r,-r 20-25; Pl.'s Mem. Opp. Summ. J. 6.) The Harringtons point to minutes from a

2007 Association meeting explaining their understanding of Seaside's assessment

4 allocation methodology. The Harringtons contend Tony LaRosa, then President of the

2 Exhibit B states "The percentage is derived by dividing the approximate square footage of each Unit (exclusive of Limited Common Elements) by the total square footage of all Units (exclusive of Limited Common Elements) and multiplying the result by 100." 3 The Harringtons assert evidence of an amendment precludes summary judgment. (Pl.'s Mem. Opp. Summ. J. 5.) ("[B]ased on the Association's admission to Plaintiffs that it had amended the Declaration, a factfinder could determine that the Association did in fact modify the Declaration to incorporate the established methodology in use through 20 11.") 4 This methodology accounted for the fact the complex is composed of two buildings: "the House" (units 1, 2, and 3) and "the Motel Building" (units 4 through 9). Rather than calculating

methodology conducted separate calculations for each building. (Pl.'s S. Addt'l M. F., the square footage and percentage allocation of Seaside as a single space, it appears the 5.)

3 Association, represented that this methodology was in effect and the Declaration would

be amended to reflect this change. (Pl.'s S. Addt'l M. F.~~ 3-10.)

Seaside denies that any amendments were made, all meetings and budgets were

legal, and all business was conducted in accordance with the Declaration and Bylaws of

the Association. (See Def. 's S.M.F. ~~ 8-28.) In moving for summary judgment on its

counterclaim, Seaside seeks the full amounts assessed by the Association to date. The

Harringtons have refused to pay more than the 2011 assessment amount, and Seaside

seeks the difference. (Def. 's Reply Pl.'s Opp. Summ. J. 3-4.)5

1. The Purported Amendment to the Declaration

Whether a condominium's declaration of rights is ambiguous is a question of law.

Farrington's Owners' Ass 'n v. Conway Lake Resorts, Inc., 2005 ME 93, ~ 10, 878 A.2d

504 (citations omitted). "Language is considered to be ambiguous if it is reasonably

susceptible to different interpretations." Acadia Ins. Co. v. Buck Canst. Co., 2000 ME

154, ~ 9, 756 A.2d 515. If ambiguous, interpreting that language is a question of fact.

Farrington's Owners' Ass 'n, 2005 ME 93, ~ 10, 878 A.2d 504.

5 Seaside also presses in its Reply that ( 1) a civil complaint filed by the Harringtons in a separate case against the Realty Company, and (2) a complaint filed with the Maine Department of Professional and Financial Regulation Real Estate Commission contain facts that contradict the Harringtons' positions in this litigation. (Def 's Reply Pl.'s Opp. Summ. J. 1-2.) This argument lacks merit.

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