Hawk Resort International, LLC v. Salt Ash Owners Association, Inc.

Supreme Court of Vermont·Decided August 21, 2026·No. 25-AP-390·Unpublished

Opinion

VERMONT SUPREME COURT Case No. 25-AP-390 109 State Street Montpelier VT 05609-0801 802-828-4774 www.vermontjudiciary.org

Note: In the case title, an asterisk (*) indicates an appellant and a double asterisk (**) indicates a crossappellant . Decisions of a three-justice panel are not to be considered as precedent before any tribunal.

ENTRY ORDER

AUGUST TERM, 2026

Hawk Resort International, LLC v. Salt Ash } APPEALED FROM: Owners Association, Inc.* } } Superior Court, Windsor Unit, Civil Division } CASE NO. 23-CV-01767 Trial Judge: H. Dickson Corbett

In the above-entitled cause, the Clerk will enter:

Defendant Salt Ash Owners Association, Inc. (SAOA) appeals from the trial court’s order in this contract dispute. The parties are involved in a development in Plymouth, Vermont. They dispute whether plaintiff Hawk Resort International (HRI) owes assessments to SAOA for HRI’s undeveloped lots. The trial court determined that HRI did not presently owe any assessments. We affirm.

I. Procedural History

A. Overview

We begin with an overview of the development project as found by the trial court. In the late 1970s, the Salt Ash Mountain Corporation began developing land on both sides of Vermont Route 100 in Plymouth, Vermont. It planned to establish a common-interest community in three separate development phases and develop various infrastructure systems, including roads, a water system, a wastewater system, and various common resources including a resort hotel, restaurant, and various amenities. Salt Ash Mountain Corporation began developing and selling lots. Individual owners formed the Salt Ash Owners’ Association.

The corporation experienced financial difficulties, and a small group of owners eventually acquired the development rights from the corporation. This owners’ group, which became HRI, created various business entities (referred to as the Hawk entities) to operate the resort amenities and develop and sell the remaining lots. These entities operated the resort and sold most of the developed-but-unsold lots but did little to develop the rest of the community. The further build-out of the resort essentially stalled.

The resort’s finances worsened due to various events. Between 2017 and 2020, SAOA became dissatisfied with the business entities that were managing the resort and acting as

developers. Litigation ensued, and the parties eventually reached a comprehensive settlement agreement in December 2019, which closed in December 2020. Pursuant to the agreement, SAOA assumed responsibility for collecting assessments and providing services within the community, while HRI was to find a new resort operator to manage the amenities and a new developer to develop and sell the remaining lots. The preparation and recording of covenants in the land records (the “HRI Covenants”) was one of the “matters subsequent to closing” that occurred as part of the implementation of the settlement agreement.

In 2021, SAOA sought to collect assessments from HRI for its undeveloped lots. HRI then filed this suit, seeking a declaration that it was not currently required to pay such assessments. SAOA filed a counterclaim, seeking an award for assessments on HRI’s undeveloped lots from January 2021 forward.

B. Partial Summary Judgment

The parties filed cross-motions for summary judgment. In a July 2024 order, the court granted HRI’s motion in part and denied SAOA’s motion. The court concluded as a matter of law that HRI’s undeveloped lots were not voting members of SAOA or subject to assessments unless: (1) the lot had frontage on and reasonable ability to connect a driveway to a common roadway, and (2) a reasonable ability to connect a building sewer to a resort sewer main.

In reaching this conclusion, the court cited the following undisputed facts. In the settlement agreement referenced above, HRI transferred to SAOA its interest in certain common lands and resort infrastructure, including the resort sewer and water systems. HRI retained certain development rights, including with respect to its “undeveloped lots,” which were described in the settlement agreement as previously created lots “that ha[d] not been developed nor had any building or structures constructed or erected thereon.”

HRI and third parties owned undeveloped lots. Pursuant to the agreement, third-party owners of undeveloped lots and third-party purchasers of undeveloped lots would become members of the SAOA. As to HRI’s undeveloped lots, however, “no membership” in the SAOA would attach and “no assessments” would be due “until such time as a common roadway is extended so that it provides reasonable driveway access to the lot and until such time as a resort sewer main has been extended so that it provides a reasonable opportunity for connection of such lot to the resort sewer main through the common areas.” The agreement further provided that “[a]n undeveloped lot that has frontage on and reasonable ability to connect a driveway to a common roadway and a reasonable ability to connect a building sewer to a resort sewer main shall be assessed by the SAOA for common area charges, road maintenance charges, and sewer charges to the same extent as any other undeveloped lot, and shall be entitled to vote as a member of the SAOA.” In other words, the court explained, the settlement agreement unambiguously provided that undeveloped lots owned by third parties would be voting members of SAOA and pay assessments, but undeveloped lots still owned by HRI would not be voting members of SAOA or pay assessments unless and until the lot had (1) frontage on and reasonable ability to connect a driveway to a common roadway, and (2) a reasonable ability to connect a building sewer to a resort sewer main.

The court found that a very similar set of agreements were then documented in the HRI Covenants, which were recorded in the land records. In these covenants, the parties agreed that third-party purchasers of lots from HRI would become members of the SAOA, but undeveloped lots still owned by HRI would not be assessed for common area charges, road maintenance charges, or common sewer charges, and could not vote as a member of the SAOA “until such

time as a common roadway is extended so that it provides reasonable driveway access to the lot and until such time as a resort sewer main has been extended so that it provides a reasonable opportunity for connection of such lot to the resort sewer main through the common areas.” The parties further agreed that HRI lots would be assessed for common area charges, road maintenance charges, sewer charges, and “such other SAOA assessments as may, from time to time, be made against all [other lot owners]” if the lot had “frontage on and reasonable ability to connect a driveway to a common roadway and a reasonable ability to connect a builder sewer to a resort sewer main.” The court found this language consistent with the settlement agreement.

The parties conceded at oral argument that HRI’s undeveloped lots were not voting members of SAOA or subject to assessments unless the lots had (1) frontage on and reasonable ability to connect a driveway to a common roadway, and (2) a reasonable ability to connect a building sewer to a resort sewer main. Even without the parties’ concession, the court found that this was the parties’ clear intent as expressed in the plain and unambiguous language of the agreements.

The parties fundamentally disagreed about how the settlement documents should be interpreted to decide which of HRI’s undeveloped lots, if any, met the requirements above. They agreed that HRI had not undertaken any development work since the date of the settlement and the HRI Covenants. The court concluded as a matter of law that the settlement documents were ambiguous as to whether any of the undeveloped lots currently met the required conditions, and a trial was required to resolve this disputed question of fact or mixed question of fact and law.

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Hawk Resort International, LLC v. Salt Ash Owners Association, Inc., (Vt. 2026).

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