Jennifer Knaack v. Henley Park Homeowners Association, Inc.

CourtCourt of Appeals of Georgia
DecidedAugust 26, 2022
DocketA22A0743
StatusPublished

This text of Jennifer Knaack v. Henley Park Homeowners Association, Inc. (Jennifer Knaack v. Henley Park Homeowners Association, Inc.) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jennifer Knaack v. Henley Park Homeowners Association, Inc., (Ga. Ct. App. 2022).

Opinion

THIRD DIVISION DOYLE, P. J., REESE, J., and SENIOR APPELLATE JUDGE PHIPPS

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. https://www.gaappeals.us/rules

August 26, 2022

In the Court of Appeals of Georgia A22A0743. KNAACK v. HENLEY PARK HOMEOWNERS ASSOCIATION, INC.

PHIPPS, Senior Appellate Judge.

In this civil action challenging the validity of home leasing limitations enacted

by defendant Henley Park Homeowners Association, Inc. (the “Association” or

“HOA”), plaintiff Jennifer Knaack, a former Association member, appeals from the

trial court’s order granting summary judgment to the Association. Knaack contends

on appeal that disputed questions of fact remain with respect to several of the trial

court’s rulings. For the reasons that follow, we reverse the trial court’s ruling that

Knaack lacks standing to bring her claim for monetary damages but affirm the grant

of summary judgment to the Association on that claim, as Knaack has not shown any

harm resulting from the Association’s actions. In addition, while we affirm the trial court’s ruling that Knaack lacks standing to bring her claim for a declaratory

judgment as to the validity of the new leasing restrictions in this direct action against

the Association, we vacate the grant of summary judgment to the Association on that

claim and remand the case for the trial court to dismiss that claim without prejudice.

Viewed in the light most favorable to Knaack, the nonmovant, see Henry v.

Griffin Chrysler Dodge Jeep Ram, 362 Ga. App. 459, 460 (868 SE2d 827) (2022), the

record shows that she bought a single family home (the “Property”) in the Henley

Park subdivision in 2011, at which time she became a member of the Association.

The Property is subject to a “Declaration of Covenants, Restrictions and Easements

for Henley Park” issued in 1990 (the “Declaration”). As relevant to this appeal,

Section 9.3 of the Declaration, which governs amendments thereto, states, in pertinent

part:

Amendments to this Declaration, [with exceptions not relevant here], shall be proposed and adopted in the following manner: (a) Notice of the subject matter of the proposed amendment shall be included in the notice of the meeting of the Association at which such proposed amendment is to be considered and shall be delivered to each Owner [of property in the subdivision]; [and] (b) at such meeting, a resolution adopting a proposed amendment may be proposed by either the [Association’s board of directors] or by Owners. Such amendment must

2 be approved by a Two-Thirds Vote[, with other exceptions not relevant here].

Knaack listed the Property for sale in or around June 2018 and moved out of

state the following month. In early August 2018, Knaack entered into an agreement

(the “Agreement”) to sell the Property for $393,000 to HP Georgia I, LLC — the

Georgia office of Home Partners of America — a company that “provides alternative

mechanisms for people to lease or lease to purchase homes.” As part of the

Agreement, HP Georgia I asked the Association to complete a questionnaire that

sought information about the Association and its leasing rules. The Agreement also

included a Buyer Addendum, which contained 18 paragraphs supplementing the

Agreement, several of which authorized HP Georgia I to terminate the Agreement

within a certain time frame or upon the occurrence or non-occurrence of various

contingencies.

On August 13, 2018, the Association’s board of directors enacted several new

Community Rules governing the leasing of homes subject to the Declaration. In

relevant part, the new rules provide:

6.1 Homeowners must own their homes for one full year (12 months) prior to being eligible to rent the home to third parties. Approval to rent

3 will be granted to homeowners by the HOA provided the rental quota limit, if any, for the subdivision has not been exceeded.

6.2 The required minimum rental period will be one year (12 months).

6.3 Each unmarried adult intending to rent a home at Henley Park shall submit a separate rental application to the [Henley Park] HOA.

6.4 Each adult intending to rent a home at Henley Park may be subject to background screening. The Association retains the right to withhold approval for rental/occupancy of any individual based on adverse background.

HP Georgia I terminated the Agreement on August 21, 2018. The written

termination form indicates, without elaboration, that the termination was based on

“the failure of the following contingency to which the Agreement is subject: Buyer

Addendum.” Another buyer bought the Property for $385,000 in April 2019.

In the interim, Knaack sued the Association in December 2018 for breach of

the Declaration and of the covenant of good faith and fair dealing.1 She alleged, inter

alia, that the Association: (i) breached the Declaration by adopting the new

Community Rules in violation of the Declaration’s amendment requirements; and

1 While Knaack initially asserted additional claims for tortious interference with contractual relations, punitive damages, and attorney fees, she later withdrew those claims.

4 (ii) breached the covenant of good faith and fair dealing by adopting the new

Community Rules for the purpose of preventing Knaack from selling the Property to

HP Georgia I. She sought monetary damages and a declaration that the new

Community Rules are void.

Following discovery, the Association moved for summary judgment. As to

Knaack’s breach-of-Declaration claim, the Association contended that: (i) Knaack’s

proposed sale to a corporate entity was barred by the Declaration; (ii) the new

Community Rules did not further restrict Knaack’s use of the Property; (iii) the new

rules were properly adopted pursuant to the Association’s Articles of Incorporation;

and (iv) regardless, Knaack cannot show that HP Georgia I terminated the Agreement

because of the new Community Rules. The Association further contended that

Knaack cannot establish a breach of the duty of good faith and fair dealing because

the Association did not breach any contractual obligations to her and that her alleged

damages are too speculative to be recoverable. During oral argument, the Association

also argued that, to the extent that Knaack claimed that the new Community Rules

constituted an unauthorized amendment to the Declaration, she lacked standing

because such a claim must be brought as a derivative action on behalf of the

5 Association. See OCGA § 14-3-740; Phoenix Airline Svcs. v. Metro Airlines, 260 Ga.

584, 585-586 (1) (397 SE2d 699) (1990).

In its order granting the Association’s motion for summary judgment, the trial

court first concluded that Knaack lacks standing to bring her claims because her

challenges to the validity of the new Community Rules, which affect all Association

members, must be brought in a derivative action. The court also ruled that,

regardless: (i) Knaack cannot establish that HP Georgia I terminated the Agreement

as a result of the adoption of the new Community Rules; (ii) the new rules did not

restrict Knaack’s rights to use the Property; (iii) the body of the Declaration

prohibited the sale of the Property to HP Georgia I regardless of any limitations

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