JOHN DARDEN v. PT HILLS CONDO, LP

CourtCourt of Appeals of Georgia
DecidedJune 24, 2025
DocketA25A0221
StatusPublished

This text of JOHN DARDEN v. PT HILLS CONDO, LP (JOHN DARDEN v. PT HILLS CONDO, LP) 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
JOHN DARDEN v. PT HILLS CONDO, LP, (Ga. Ct. App. 2025).

Opinion

THIRD DIVISION DOYLE, P. J., MARKLE and PADGETT, JJ.

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

June 24, 2025

In the Court of Appeals of Georgia A25A0221. DARDEN et al. v. PT HILLS CONDO, LP et al.

PADGETT, Judge.

John Darden and others (“Buyers”) appeal from the trial court’s dismissal of

their claims for fraud and non-disclosure against PT Hills Condo, LP and PT Hills

Place Club, LLC (together, “Defendants”), arising out of their purchase of

condominium units in a senior retirement community. For the reasons set forth below,

we affirm in part, vacate in part, and remand with direction.1

On appeal, we apply a de novo standard of review to a trial court’s grant of a

motion to dismiss. Weathers v. Dieniahmar Music, LLC, 337 Ga. App. 816, 817 (788

SE2d 852) (2016). We “construe the pleadings in the light most favorable to the

1 Oral argument was held in this case on February 26, 2025. A link to the video can be found on this Court’s website. appellant with all doubts resolved in the appellant’s favor.” Id. (citation and

punctuation omitted). A motion to dismiss may be granted “only where a complaint

shows with certainty that the plaintiff would not be entitled to relief under any state

of facts that could be proven in support of his claim.” Goldston v. Bank of America, 259

Ga. App. 690, 690-691 (577 SE2d 864) (2003) (citation and punctuation omitted).

So viewed, the record shows that Buyers, most of whom are over 75 years old,

separately bought condominiums at Peachtree Hills Place, a senior retirement

community owned and operated by Defendants. Buyers signed separate purchase

agreements between 2016 and 2022 and closed between 2019 and 2022. A mandatory

one-time entrance fee of $100,000 provided them access to recreational facilities (the

“Club”) as well as to a separate medical facility (“The Terraces”) offering assisted

living, memory care, and skilled nursing on a fee-for-service basis. Buyers agreed to

pay monthly Club fees that were “subject to increase if ‘necessary’ in order ‘to meet

the financial needs of operating the Community.’” As part of the sales process,

Buyers signed acknowledgments of receipt of a disclosure package which they allege

was incomplete. In November 2023, Buyers sued Defendants asserting claims

including that Defendants were fraudulently concealing conflicts of interest and self-

2 dealing during the purchase process in violation of the Georgia Condominium Act (the

“Condominium Act”), OCGA § 44-3-111 (Count I) and failed to provide disclosures

required by continuing care providers and facilities under OCGA § 33-45-10 (Count

II). Buyers also sought a declaration that provisions of undisclosed lease agreements

pertaining to the Club and Terraces were illegal and unenforceable because they

required Buyers to pay higher monthly fees without their consent (Count IV(A)). In

addition, Buyers claimed PT Hills Condo’s permanent control of the condominium

association (to the exclusion of the residents) is unlawful and unconscionable, entitling

Buyers to declaratory relief, reformation, and/or rescission (Counts IV(B) and V).2

Defendants moved to dismiss these counts for failure to state a claim upon which

relief could be granted under OCGA § 9-11-12 (b) (6), arguing that (1) the

Condominium Act claim was barred by the applicable one-year statute of limitation,

(2) Defendants provided any disclosures under OCGA § 33-45-10, (3) Buyers could

not rescind their purchase agreements because there was no offer to tender, and (4)

Buyers did not have standing to assert the declaratory judgment and reformation

2 The original complaint asserted five Counts. It was later amended to add a Count VI for breach of tolling agreements. Defendants sought to dismiss only Counts I, II, IV, V, and VI; Count III remains pending. Buyers do not challenge the dismissal of Count VI with this appeal. 3 claims. One of the Buyers, Candace A. McNair, moved for partial summary judgment

as to Counts I, II, and IV(A). The trial court granted Defendants’ motion to dismiss

, and Buyers filed a motion for reconsideration. In a separate order, the trial court

denied McNair’s motion for partial summary judgment as moot. Following a hearing,

the trial court denied Buyers’ motion for reconsideration but issued certificates of

immediate review of that order and the order denying summary judgment. This Court

granted Buyers’ applications for interlocutory appeal , and this appeal followed.

1. In their first enumeration of error, Buyers contend that the trial court erred

by granting Defendants’ partial motion to dismiss on Counts I, II, IV, and V and in

denying their motion for reconsideration.

(a) Count I - Georgia Condominium Act Claim

Buyers contend that the trial court erred in dismissing the Condominium Act

Claim because (i) the applicable limitations period was controlled by OCGA § 44-3-

111 (i) (4) and (ii) Defendants’ fraud tolled the statute of limitation. We disagree.

Under the Condominium Act, any action against the seller for missing or

misleading information under OCGA § 44-3-111 must be made

4 at any time prior to the expiration of one year after the date upon which the last of the events described in paragraphs (1) through (5) of this subsection shall occur:

(1) The closing of the transaction;

...

(4) As to claims relating to the common elements and other portions of the condominium which are the responsibility of the association to maintain, the date upon which the declarant’s right to control the association terminates as provided in Code Section 44-3-101 . . .

OCGA § 44-3-111 (i).

(i) Here, Buyers do not dispute that they filed the lawsuit more than a year after

closing. They argue, however, that the Club and Terraces qualify as “other portions

of the condominium which are the responsibility of the association to maintain”3 and

3 Buyers do not seem to contend that the Club and Terraces be considered as common elements, but the same logic applies. “Common elements” of a condominium are defined by the Condominium Act as “portions of the condominium other than the units.” OCGA § 44-3-71 (4). 5 therefore, the statute of limitation does not begin to run until PT Hills Condo’s rights

under OCGA § 44-3-101 have terminated.4 OCGA § 44-3-111 (i) (4). We disagree.

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