Jeremy Kooiman v. Jeffrey Ornoff

CourtCourt of Appeals of Virginia
DecidedJanuary 30, 2024
Docket1760221
StatusUnpublished

This text of Jeremy Kooiman v. Jeffrey Ornoff (Jeremy Kooiman v. Jeffrey Ornoff) 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
Jeremy Kooiman v. Jeffrey Ornoff, (Va. Ct. App. 2024).

Opinion

COURT OF APPEALS OF VIRGINIA

Present: Judges O’Brien, AtLee and Malveaux UNPUBLISHED

Argued at Norfolk, Virginia

JEREMY KOOIMAN, ET AL.

v. Record No. 1758-22-1

JEFFREY ORNOFF MEMORANDUM OPINION* BY JUDGE RICHARD Y. ATLEE, JR. JEREMY KOOIMAN, ET AL. JANUARY 30, 2024

v. Record No. 1760-22-1

JEFFREY ORNOFF

FROM THE CIRCUIT COURT OF ISLE OF WIGHT COUNTY Lawson Wayne Farmer, Judge

Norman A. Thomas (Norman A. Thomas, PLLC, on briefs), for appellants.

Bryan S. Peeples (Pender & Coward, P.C., on brief), for appellee.

Appellants Jeremy and Lucy Kooiman appeal the circuit court’s rulings granting injunctive

relief against them and denying injunctive relief against their neighbor, Jeffrey Ornoff. The circuit

court interpreted certain restrictive covenants to prohibit the Kooimans from renting out their

basement apartment for short-term rentals. The circuit court also found that Ornoff did not violate a

separate restrictive covenant that prohibited the use of cinder blocks on the “exterior side” of

buildings. On appeal, the Kooimans argue that the circuit court erred in its interpretation of the

restrictive covenants, by granting Ornoff relief that he did not seek in his complaint, and by denying

them due process by granting Ornoff relief requested post-trial without giving the Kooimans the

* This opinion is not designated for publication. See Code § 17.1-413(A). opportunity to be heard. For the following reasons, we disagree and affirm the decision of the

circuit court.

I. BACKGROUND1

The Kooimans and Ornoff are neighbors in an Isle of Wight County subdivision that was

platted and developed in 1966. Ornoff’s property is designated lot 26, while the Kooimans own lot

25. Each of the properties in the subdivision are encumbered by eight deed restrictions that run with

the land. At issue in this appeal are restrictions one, three, and four, which provide:

1. Said real estate shall be used solely and exclusively for residential purposes, and no structures shall be erected, altered, placed or permitted to remain on said real estate, other than a single family dwelling, not to exceed two stories in height . . . .

....

3. All buildings on said lot shall be constructed of frame or masonry material or a combination of the two except that no exterior side shall be of cinder block, asbestos shingles, or combination asphalt siding material.

4. No trailer, basement, tent, shack, garage, barn, boat house or other outbuilding erected or placed on said real estate shall at any time be used as a residence, temporarily or permanently.

Both parties filed suit against the other seeking to enforce the restrictive covenants.2

A. Ornoff’s suit against the Kooimans

At the time Ornoff purchased his lot in 2012, the neighboring lots were empty. In 2016, the

Kooimans purchased one of the empty lots next to Ornoff’s property and built a house. The house

1 The parties have a long and tortured history, including a separate lawsuit and complaints with zoning authorities. Because those details are not relevant to the issues before us on appeal, we do not include them. 2 Both suits were consolidated and tried together, though we list the facts relevant to each case separately for clarity. The circuit court ruled against the Kooimans in both cases, and they appealed the rulings in both cases. We resolve both appeals in this memorandum opinion. -2- included a finished basement with a separate apartment,3 which, beginning in 2018, the Kooimans

listed for rent on both Airbnb and VRBO. Mr. Kooiman testified that they hosted Airbnb or VRBO

guests “on average maybe two weekends a month, some months we have nothing and some

months we have four.” On occasion, the Kooimans also allow family members to stay in the

apartment.

Ornoff filed a complaint seeking injunctive relief to enforce the restrictive covenants.

Relevant here, his complaint asked the circuit court to “issue a permanent and perpetual

injunction ordering [the Kooimans] to restore their basement apartment to an unfinished

basement[ and] cease using any part of their home as a short-term rental business.” It also asked

for “such further and general relief as the nature of this case may require or this Honorable Court

sees fit.”

At trial, the Kooimans represented themselves. Mrs. Kooiman denied that their basement

constituted a separate residence or apartment, though she admitted they host paying guests.

Mr. Kooiman testified that they use the basement as part of their home. He testified that the

paying guests lack the rights and privileges typically associated with a “residence,” noting,

among other things, that they do not have a lease, do not receive mail, cannot set house rules, and

cannot control the HVAC or hot water temperature.

During closing arguments, the Kooimans relied on Scott v. Walker, 274 Va. 209 (2007),

which held that a short-term rental of a house did not violate a “residential purpose” requirement

in a restrictive covenant. They argued that the short-term rental of their basement was likewise a

“residential purpose.” They also argued that restriction four did not prohibit the short-term

rentals because the paying guests never establish a “residence” in the basement.

3 At trial, the Kooimans disagreed that it was an apartment. The basement includes two bedrooms, a full bath, a living room, a dining room, and a kitchen. It has a separate entrance, but it can also be accessed from the upstairs. The circuit court found it was an apartment. -3- Ornoff argued that payment for use of the basement was a commercial, rather than

residential, purpose. He pointed out that the basement was used as a living area separate from

the rest of the house, and he argued that restrictions one and four, when read together, prohibited

using the basement as a short-term rental. He also distinguished Scott v. Walker, arguing that

that case involved a single, ambiguous restriction, while this case involved two restrictions that,

when read together, were clear and unambiguous.

The circuit court took the issue under advisement and allowed the parties to submit letters

with additional case law and argument. On September 9, 2022, the circuit court issued its ruling

orally. It acknowledged that restrictive covenants are not favored but noted that they are

enforceable if they are clear in their meaning. It found that the language in restrictions one and

four, when read together, is clear. The circuit court pointed out the inherent contradiction in

arguing that the short-term rental is not a “residence” but that it is a “residential purpose.” It

made three specific rulings:

One, the [Kooimans] may not permit any person to occupy the basement as a separate residence or for living purpose that are separate from the primary residence. It cannot be a separate residence or separate living area separate from the primary residence for anyone. Two, the [Kooimans] may not rent, lease, or any way convey the basement to be used as a separate residence for living purposes, no matter how brief. And, three, the [Kooimans] shall be responsible for any attorney’s fees and costs associated with the enforcement of this injunction.

The circuit court refused to order the Kooimans to remove any structures within the basement

that rendered it a separate residence. It noted that the restriction did not require the basement

only be used for storage, and it acknowledged that there were ways that the Kooimans could use

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