JAMES HALLECK HOELAND, Trustee v. CONSERVATION COMMISSION OF WELLFLEET.

CourtMassachusetts Appeals Court
DecidedMay 7, 2025
Docket23-P-1304
StatusUnpublished

This text of JAMES HALLECK HOELAND, Trustee v. CONSERVATION COMMISSION OF WELLFLEET. (JAMES HALLECK HOELAND, Trustee v. CONSERVATION COMMISSION OF WELLFLEET.) 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
JAMES HALLECK HOELAND, Trustee v. CONSERVATION COMMISSION OF WELLFLEET., (Mass. Ct. App. 2025).

Opinion

NOTICE: Summary decisions issued by the Appeals Court pursuant to M.A.C. Rule 23.0, as appearing in 97 Mass. App. Ct. 1017 (2020) (formerly known as rule 1:28, as amended by 73 Mass. App. Ct. 1001 [2009]), are primarily directed to the parties and, therefore, may not fully address the facts of the case or the panel's decisional rationale. Moreover, such decisions are not circulated to the entire court and, therefore, represent only the views of the panel that decided the case. A summary decision pursuant to rule 23.0 or rule 1:28 issued after February 25, 2008, may be cited for its persuasive value but, because of the limitations noted above, not as binding precedent. See Chace v. Curran, 71 Mass. App. Ct. 258, 260 n.4 (2008).

COMMONWEALTH OF MASSACHUSETTS

APPEALS COURT

23-P-1304 23-P-1305

JAMES HALLECK HOELAND, trustee, 1

vs.

CONSERVATION COMMISSION OF WELLFLEET.

MEMORANDUM AND ORDER PURSUANT TO RULE 23.0

The plaintiff, James Halleck Hoeland, as "Trustee of the

Family Trust Established Under Article IV, Paragraph (E)(1) of

the Grantor Retained Annuity Trust of Mark Blasch Dated October

23, 2008" (trust), appeals from a Superior Court judgment

affirming the decision of the defendant conservation commission

of Wellfleet (commission) to deny the trust's application to

construct a coastal engineering structure (CES) on a coastal

bank located on the trust's property. Because the local

1Of the Family Trust Established Under Article IV, Paragraph (E)(1) of the Grantor Retained Annuity Trust of Mark Blasch Dated October 23, 2008. environmental protection regulations are more restrictive than

State regulations, we affirm.

Background. 1. The trust's project. The trust owns

property in Wellfleet that contains a single-family residential

dwelling constructed in 2010. 2 The property also contains a

costal bank as defined in the Wetlands Protection Act, G. L.

c. 131, § 40 (act), and the State regulations promulgated

thereunder (State regulations). See 310 Code Mass. Regs.

§ 10.30 (2014). 3 The dwelling is located near the top of the

eroding coastal bank. 4 On September 12, 2018, the trust filed a

notice of intent (NOI) with the commission seeking an order of

conditions under the provisions of the act, the Wellfleet

environmental protection bylaw (bylaw), and the Wellfleet

environmental protection regulations (local regulations), to

2 The property contained a dwelling prior to August 10, 1978. In 2007, the commission issued an order of conditions authorizing the demolition of the structure and the construction of the dwelling at issue here.

3 Unless otherwise noted, all references to the State regulations are to the 2014 version, which was in effect in 2018 when the trust filed its notice of intent. A coastal bank is defined in 310 Code Mass. Regs. § 10.30(2) as "the seaward face or side of any elevated landform, other than a coastal dune, which lies at the landward edge of a coastal beach, land subject to tidal action, or other wetland."

4 In 2018, the dwelling's foundation and deck were located within twenty-five feet and fourteen feet, respectively, from the top of the coastal bank. Those distances have since decreased.

2 construct a CES on the coastal bank to prevent further erosion

and protect the dwelling. Pursuant to the State and local

regulations, the commission may permit a CES on a coastal bank

to prevent damage to buildings constructed prior to August 10,

1978. 5 See 310 Code Mass. Regs. § 10.30(3). In November 2018,

the trust revised the proposal and submitted additional

materials to the commission. The proposed CES consisted of a

241-foot-long rock revetment, covered with fiber rolls and a

planted sand cover, with annual sand nourishment.

2. First decision and proceedings. In December of 2018,

after a public hearing, the commission voted to deny the NOI.

In its decision, the commission found that the trust was not

entitled to a CES under the local regulations because the

dwelling on the property was constructed in 2010 and since

August 10, 1978, "two separate dwellings have been built and

removed from the site." It also found that the "armoring" of

the property through the construction of a CES "is likely to

lead to significant erosion on abutting properties."

On February 1, 2019, the trust brought an action in the

nature of certiorari in the Superior Court pursuant to G. L.

5As discussed infra, the State regulations also provide that a CES may be permitted to protect post-August 10, 1978 reconstructions of pre-August 10, 1978 structures. See 310 Code Mass. Regs. § 10.30(3).

3 c. 249, § 4. On April 24, 2020, a judge allowed the trust's

motion for judgment on the pleadings. The judge found that the

commission was required to include a "specific condition"

pursuant to 310 Code Mass. Regs. § 10.30(5), in the 2007 order

of conditions that no CES shall be permitted "if at that time it

deemed the reconstruction of the structure to be a 'new

building,'" i.e., one constructed for the first time after

August 10, 1978. 6 The judge acknowledged that the local

regulations were more stringent than the act in that they did

not "allow[] for the protection of pre-1978 buildings

'reconstructed' after 1978," but concluded that the denial of

the NOI on the basis of categorizing the structure as "[post]-

1978" was arbitrary and capricious in light of the absence of

the specific condition. 7 The judge remanded the matter to the

6 Title 310 Code Mass. Regs. § 10.30(5) provides that the order of conditions and certificate of compliance for "any new building within 100 feet landward of the top of a coastal bank permitted by the issuing authority" under G. L. c. 131, § 40, must contain the following condition: "310 CMR 10.30(3), promulgated under [G. L. c. 131, § 40], requires that no coastal engineering structure, such as a bulkhead, revetment, or seawall shall be permitted on an eroding bank at any time in the future to protect the project allowed by this [o]rder of [c]onditions."

7 The judge further concluded that (1) the commission's denial of the application "based on findings of insufficient information" provided by the trust was not supported by substantial evidence and was thus arbitrary, and (2) the commission "applied a too stringent interpretation" of the "no feasible alternative" requirement and imposed an undue burden on the trust.

4 commission to "consider the proposal anew" based on the

"information provided to it." 8

On May 7, 2020, the trust filed a motion in the Superior

Court to vacate the judgment and reconsider the April 24, 2020

decision. The trust asked the Superior Court judge to (1) order

the commission to treat the dwelling as a pre-August 10, 1978

structure on remand, (2) consider the proposal based on the

administrative record alone, and (3) retain jurisdiction over

the matter pending the commission's reconsideration of the NOI.

On June 22, 2020, the judge, treating the motion as one to alter

and amend, agreed that the Superior Court would retain

jurisdiction and instructed that, upon remand, "the [c]ommission

should review the proposal pursuant to section 2.03(2) of the

bylaw, which authorizes the [c]omission to allow a CES provided

certain requirements are met." The judge concluded that the

record contained "sufficient information for the [c]ommission to

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JAMES HALLECK HOELAND, Trustee v. CONSERVATION COMMISSION OF WELLFLEET., Counsel Stack Legal Research, https://law.counselstack.com/opinion/james-halleck-hoeland-trustee-v-conservation-commission-of-wellfleet-massappct-2025.