Longhorn Creek Ltd. v. Gardens of Connemara Ltd. and Emerson Farm Company, Ltd.

CourtCourt of Appeals of Texas
DecidedFebruary 20, 2024
Docket05-22-00842-CV
StatusPublished

This text of Longhorn Creek Ltd. v. Gardens of Connemara Ltd. and Emerson Farm Company, Ltd. (Longhorn Creek Ltd. v. Gardens of Connemara Ltd. and Emerson Farm Company, Ltd.) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Longhorn Creek Ltd. v. Gardens of Connemara Ltd. and Emerson Farm Company, Ltd., (Tex. Ct. App. 2024).

Opinion

Reverse and Remand and Opinion Filed February 20, 2024

In The Court of Appeals Fifth District of Texas at Dallas No. 05-22-00842-CV

LONGHORN CREEK LTD., Appellant V. GARDENS OF CONNEMARA LTD. AND EMERSON FARM COMPANY, LTD., Appellees

On Appeal from the 429th Judicial District Court Collin County, Texas Trial Court Cause No. 429-00851-2022

OPINION Before Chief Justice Burns, Justice Molberg, and Justice Carlyle Opinion by Justice Molberg This appeal concerns the granting of appellees Gardens of Connemara Ltd.

and Emerson Farm Company, Ltd.’s rule 91a motion to dismiss appellant Longhorn

Creek Ltd.’s declaratory judgment action. Longhorn Creek argues the trial court

erred in granting the rule 91a motion because its claim for declaratory relief had a

basis in fact and law. Because we agree, we reverse and remand.

I. Background

Longhorn Creek filed suit on February 21, 2022. It alleged Connemara and

Emerson filed a conservation easement assessment agreement and declaration providing for a “private transfer fee” of one percent of the value of conveyed land

for all land covered by the agreement. Longhorn Creek alleged the fee applied to

any conveyance, including granting, selling, assigning, and transferring any

possessory interest or estate in the land. Longhorn Creek alleged it owned property

that Connemara and Emerson claimed was subject to the private transfer fee

obligation. It sought a declaration it was not obligated to pay the private transfer fee

because (1) Connemara and Emerson had failed to file statutorily compliant notices

pursuant to Texas Property Code § 5.203, (2) Connemara and Emerson waived the

fee obligation based on subsequent amendments to the assessment agreement and

releases of multiple parties from their transfer fee obligations, (3) the private transfer

fee covenant does not touch and concern the property, and (4) the private transfer

fee is ineffective or void as to the property.

On May 16, 2022, Connemara and Emerson filed a rule 91a motion to dismiss,

arguing Longhorn Creek’s claim had no basis in law or fact.

On June 16, 2022, Longhorn Creek filed an amended petition for declaratory

relief. Longhorn Creek alleged that, in 2005, Connemara, Emerson, and two other

entities1 entered into a written agreement titled, “Conservation Easement

Assessment Agreement and Declaration,” which Connemara filed in the real

property records of Collin County. Longhorn Creek attached a copy of the

1 The other two entities are Montgomery Farm Company and Bethany Corner, Ltd. We will hereinafter refer solely to the two appellees before us, Connemara and Emerson. –2– assessment agreement to its amended petition as Exhibit A. The assessment

agreement, among other things, required the payment of a fee equal to one percent

of the value of conveyed land (“private transfer fee” or “fee”) for all land covered

by the agreement. Longhorn Creek alleged the fee purported to last in perpetuity,

burdening all subsequent purchases of land covered by the assessment agreement.

On its face, Longhorn Creek alleged, the private transfer fee sought to “encumber

and extract value ad nauseam from all transactions involving a transfer of the ‘bundle

of rights’ inherent to both residential and commercial sales, as well as leases and

inheritances.”

Longhorn Creek alleged it purchased property2 in Allen, Texas, in February

2021, and Connemara and Emerson claimed the property was subject to the private

transfer fee obligation.

Longhorn Creek alleged the assessment agreement had been amended

numerous times. It alleged multiple parties had secured “partial releases” whereby

the party paid a one-time 1.1 percent fee at sale instead of paying one percent transfer

fees on all subsequent leases of the property. Longhorn Creek here cited exhibits

B-1 through B-11, “true and correct copies of the amendments and releases,”

attached to its amended petition. For example, Longhorn Creek alleged Connemara

and Emerson released certain residential properties on December 11, 2019, from the

The amended petition stated the description of the property as “WATTERS CREEK AT 2

MONTGOMERY FARM PHASE 1, BLK A, LOT 3R-1A.” –3– assessment agreement obligations, and that Connemara and Emerson had not

collected any fees on residential property sales since that date.

Longhorn Creek next discussed in its amended petition the passage in 2011 of

legislation relating to private transfer fees. The legislature adopted Chapter 5,

Subchapter G, of the Texas Property Code to regulate private transfer fees.3 The

legislation made private transfer fee obligations created on or after June 17, 2011,

void and unenforceable against a subsequent owner or purchaser of real property.

TEX. PROP. CODE § 5.202(a). Fee obligations created before then were made subject

to strict notice requirements, which the parties agree must be strictly complied with

or else the obligations may become void. A person receiving such a private transfer

fee is required to file a notice of the private transfer fee obligation in the real property

records of the county in which it is located. Id. § 5.203(a). The notice is required to

(1) be printed in at least fourteen-point boldface type; (2) state the amount of the fee

and any method of determination; (3) state the date or any circumstance under which

the fee obligation expires, if any; (4) state the purpose for which the money from the

fee obligation is to be used; (5) state the name of each payee and each payee’s contact

information; (6) state the name and address of the payee of record to whom the

3 The Code defines “private transfer fee” as “an amount of money, regardless of the method of determining the amount, that is payable on the transfer of an interest in real property or payable for a right to make or accept a transfer.” TEX. PROP. CODE § 5.201(4). “Private transfer fee obligation” means an obligation to pay a private transfer fee created under “(A) a declaration or other covenant recorded in the real property records in the county in which the property subject to the private transfer fee obligation is located; (B) a contractual agreement or promise; or (C) an unrecorded contractual agreement or promise.” Id. § 5.201(5). –4– payment of the fee must be sent; (7) include the acknowledged signature of each

payee or authorized representative of each payee; and (8) state the legal description

of the property subject to the private transfer fee. Id. § 5.203(c). Additionally, a

person required to file a notice of a private transfer fee obligation must refile the

notice every three years thereafter. See id. § 5.203(d). Failure to comply with these

“strict notice requirements” subjects the party seeking the fee to certain

consequences, including the voiding of the private transfer fee obligation. Id.

§ 5.203(f). Longhorn Creek attached an attorney general’s opinion discussing these

provisions as Exhibit C.4

Longhorn Creek alleged Connemara and Emerson filed its § 5.203 notice in

2012 and refiled it in 2015, 2018, and 2021, and it attached copies of the notices to

its amended petition as exhibits D through G. It alleged Connemara and Emerson’s

notices failed to adhere to the statutory requirement of stating the legal description

of the property subject to the private transfer fee obligation and failed to provide the

legal description of the property in at least fourteen-point boldface type. Instead,

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