Liotta, C. v. Hawkins, R.

CourtSuperior Court of Pennsylvania
DecidedJuly 16, 2024
Docket321 WDA 2023
StatusUnpublished

This text of Liotta, C. v. Hawkins, R. (Liotta, C. v. Hawkins, R.) is published on Counsel Stack Legal Research, covering Superior Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Liotta, C. v. Hawkins, R., (Pa. Ct. App. 2024).

Opinion

J-A22033-23

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

CHRISTINE LIOTTA, CHESTER A. JR. : IN THE SUPERIOR COURT OF & BRENDA KROKOSKI, ERNEST F. & : PENNSYLVANIA DARLA J. KEMPER, CYNTHIA G. : SMITH, DENIS C. & PAMELA A. : WAGNER, DAVID DIETZ, DAWN R. : CAIARELLI, KATHLEEN M. BEITH AND : MARLIYN CONTI : : : v. : : : ROBERT FOSTER HAWKINS AND : INDE LEE HAWKINS : : Appellants : No. 321 WDA 2023

Appeal from the Order Entered March 13, 2023 In the Court of Common Pleas of Venango County Civil Division at No(s): Civil No. 814-2021

BEFORE: BOWES, J., OLSON, J., and KING, J.

MEMORANDUM BY KING, J.: FILED: July 16, 2024

Appellants, Robert Foster Hawkins and Inde Lee Hawkins, appeal from

the order entered in the Venango County Court of Common Pleas, enjoining

Appellants from using their property as a short-term rental. We affirm.

The trial court set forth the relevant facts and procedural history of this

case as follows:

[Appellants and Appellees] are all owners of lots located on River Drive in Sandycreek Township, Venango County, Pennsylvania. All ten lots in question abut the Allegheny River and were previously owned by Edward H. Culbertson and Ruth A. Culbertson. Commencing in the 1960’s, the Culbertsons subdivided this large tract of land into smaller lots along the river. The various deeds submitted into J-A22033-23

evidence refer to a specific lot number or numbers from the plan known as “Bucktail Trails” originally surveyed in 1963 and revised in 1980.

Vehicular access to the lots is by a private road, namely River Drive owned by the Franklin Belmar Drive Road Association, Inc. [(“Road Association”)]. All the lot owners are members of the Road Association. River Drive … is described in seven of the deeds submitted as an appurtenance to the parcels conveyed as a means of ingress, egress and regress to and from Liberty Street, City of Franklin, Pennsylvania. The deeds also set forth annual payments for use and maintenance of the road. An eighth deed simply states, subject to all the restrictions, leases, covenants, agreements, R-O-W and easements conveyed in or granted in prior instruments. A ninth deed states, subject to exceptions, reservations, conditions, right of way, and reservations as are contained in prior deeds in the chain of title….

[Appellants] purchased real property at 1094 River Drive, Franklin, Pennsylvania via deed dated September 29, 2019. The land was described in the deed as “Lots number 20 and 20A on that certain Plan of Lots designated ‘Bucktail Trails’”….

Thirteen months after purchase, [Appellants] began advertising their property through Airbnb for short-term rental. Neighbors brought to the attention of [Appellants] that they were in violation of the zoning code. [Appellees] requested a hearing before the Township board of supervisors. The board found the use of the premises was the equivalent of a Bed and Breakfast and was a permissible conditional use. A conditional use permit was granted.

[On September 29, 2021, Appellees filed a complaint seeking enforcement of a restrictive covenant in Appellants’ deed to enjoin Appellants from operating an Airbnb on their property. Appellees alleged that] the operation of a short- term rental by [Appellants] at 1094 River Drive violates the use and building restrictions set forth in the deeds the Culbertsons created for the plan of lots known as “Bucktail Trails.” The restrictive use and building requirements set forth in [Appellants’] deed [is as] follows:

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Subject also to the covenants and restrictions that the above described premises shall be used for residential and noncommercial recreational purposes only and no buildings shall be erected or used thereon except a private dwelling and a private garage; and that no house trailer, bus or vehicle, or former vehicle, shall be, used on said premises for dwelling purposes and these covenants shall be considered and construed as covenants running with the land.

Six of [Appellees’] deeds contain the same verbatim restriction. One deed restricts the use of the land to non- commercial recreational purposes only, as building of any kind for residential, commercial, business or industrial use was restricted.

(Trial Court Opinion, filed 3/2/23, at 1-3).

On July 14, 2022, the court conducted a non-jury trial. Appellee Ernest

Kemper testified that he and his wife have owned the property directly next

to Appellants’ property for ten years. The Kempers reside at their River Drive

home for approximately seven to eight months out of the year. During the

remaining months, they typically visit the River Drive property every other

week. Mr. Kemper testified that one of the incentives to purchasing this

property was the restrictive covenant contained in the deeds, restricting the

use of the properties to residential, non-commercial use. Mr. Kemper testified

that he and his wife did not want to invest into a community with a high

turnover of people.

Since Appellants have begun renting their property on Airbnb, Mr.

Kemper has noticed new renters entering and leaving Appellants’ property

nearly daily. Some renters stay for a few days, but the vast majority stay for

-3- J-A22033-23

one day at a time. The renters often bring pets, which has increased the level

of noise in the neighborhood. It has also increased the vehicular traffic in the

neighborhood, as renters and cleaning services are constantly arriving and

leaving the property. Some of the renters have trespassed on the Kempers’

property to launch kayaks into the river, which is particularly concerning to

Mr. Kemper because he is worried that someone may be injured on his

property. Mr. Kemper testified that the constant rotation of unknown

individuals in Appellants’ property has made him uneasy and has resulted in

him changing the way that he utilizes his property. He now ensures that

everything on his property is always locked and no longer feels comfortable

allowing his young grandchildren to play outside without an adult present.

Appellee Christine Liotta testified that she has owned a property on River

Drive since 2006. She stated that she was aware of the restrictive covenants

affecting the properties on the road when she purchased her property. Ms.

Liotta’s understanding of the covenants at the time of purchase was that she

would be purchasing a home on a private road in a gated, residential

community. This was a motivating factor in her purchase of the property.

River Drive is a private road that is gated at two access points. It is owned

by the Road Association, and Ms. Liotta serves as the Vice President of the

Association. All residents along the road pay dues for the maintenance of the

road. The dues were raised from $350.00 to $400.00 in recent years. Many

properties have garages that are across the street from their properties, so it

-4- J-A22033-23

is very common for residents to walk back and forth on the road. Children

also often play on the road. Ms. Liotta recalled that when her children were

growing up, she generally felt comfortable letting them play out of her sight

because it was a gated, residential community and she generally knew

everyone that would be entering the area.

Ms. Liotta testified that prior to Appellants’ use of their property as an

Airbnb, there were very few strangers coming down the street other than

delivery trucks. Since the Airbnb has been operating, many unknown renters

use the road. The Road Association has had to increase their liability insurance

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Bluebook (online)
Liotta, C. v. Hawkins, R., Counsel Stack Legal Research, https://law.counselstack.com/opinion/liotta-c-v-hawkins-r-pasuperct-2024.