Oliver v. Loudoun County Board of Supervisors

85 Va. Cir. 15, 2011 WL 11521153, 2011 Va. Cir. LEXIS 267
CourtLoudoun County Circuit Court
DecidedDecember 2, 2011
DocketCase No. (Civil) 63889
StatusPublished

This text of 85 Va. Cir. 15 (Oliver v. Loudoun County Board of Supervisors) is published on Counsel Stack Legal Research, covering Loudoun County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Oliver v. Loudoun County Board of Supervisors, 85 Va. Cir. 15, 2011 WL 11521153, 2011 Va. Cir. LEXIS 267 (Va. Super. Ct. 2011).

Opinion

By Judge Burke F. McCahill

Plaintiffs commenced this action to establish an equitable servitude and for injunctive relief on September 29,2010. The Court heard testimony and argument in this matter on November 10 and 11, 2011. At the conclusion of the plaintiffs’ case-in-chief, the County moved to strike the plaintiffs’ case, which the Court denied. The Defendant then introduced evidence. The County did not renew its motion to strike at the conclusion of the trial. The Court took this matter under advisement and now finds as follows.

The property at issue is located in the Little River Farms subdivision (Little River Farms) of Aldie, Virginia. Little River Farms was originally one parcel of land. In 2005, Little River Farm, L.L.C. (the Developer) purchased this parcel for the purpose of developing an upscale residential community. In August 2005, the Developer received funding from Branch Banking & Trust Co. (BB&T) to develop the parcel into twenty-one single family lots. In April 2006, the Developer submitted a Land Development [16]*16Application to the County to develop Section 1 of Little River Farms, comprised of lots 1-4, 18, and 19 (Section 1). The application reflects that the proposed project was for six single family detached lots. In August 2006, the Developer submitted a Land Development Application to the County to develop Section 2 of Little River Farms, comprised of lots 5-17, 20, and 21 (Section 2), which reflects that the proposed project was for fifteen single family detached lots. The County approved both applications and acknowledged in the cover sheet to the approval for Section 1 that “[t] he purpose of this construction plan and profile is to develop six single family detached homes.” See Plaintiffs’ Exhibit # 12.

On December 19,2006, the Developer recorded a Deed of Subdivision, Dedication, and Easement for Section 1, along with a plat depicting the lots in Section 1. On May 1,2007, the Developer recorded a Deed of Subdivision, Dedication, and Easement for Section 2, along with a plat depicting the lots in Section 2. Note 6 on the plats for Sections 1 and 2 indicates that the proposed use for the property is “single family detached residential.” The plats also show that septic tanks and wells were to be installed on each lot as part of the development of the property. The Developer obtained sewage disposal permits and well/water permits from the County for the lots.

The Developer had previously obtained, in December 2005, a zoning permit from the County to display an advertisement sign on the property. In addition to displaying a sign, the Developer maintained a sales office and website. Little River Farms was advertised exclusively as a single family detached residential community. In April 2007, the Developer sold its first lot, Lot 2, to Plaintiffs John and Norma Cusack. The Developer sold Lot 4 to Plaintiffs Lynn and J. Colette Oliver also in April 2007. In August 2007, the Developer sold Lot 5 to Plaintiffs Robert and Catherine Spicer. Plaintiffs Jonathan and Victoria Redgrave own Lot 1 of Little River Farms.

Prior to purchasing their homes in Little River Farms, the plaintiffs were shown a Declaration of Covenants, Conditions, Restrictions, and Reservation of Easements (the Covenants). The Covenants provide, in relevant part, that “[ejach Lot shall be used, improved, and devoted exclusively for residential purposes only” and that “[n]o structure shall be erected, placed, or permitted to remain on any Lot other than one detached single-family residence.” Although the Developer intended to record the Covenants, the Covenants were not actually recorded on the land records of the County.

On July 15,2008, Dawn Klassen, the Land Acquisition Manager for the County, contacted the Developer about a possible sale of two lots in the subdivision to the County for use as the new Aldie Fire & Rescue Station. During this time, the Developer was experiencing financial hardships, and, on July 31, 2008, the Developer received a Notice of Default from counsel for BB&T. On October 10, 2008, the Developer and the County entered into a Real Estate Sales Contract, whereby the County purchased Lots [17]*1718 and 19. The same day that the Developer and the County signed the Deed, November 19,2008, the Developer also signed an Owner’s Affidavit at settlement stating that the current use for Lots 18 and 19 is “single family residence.” The Developer subsequently entered into a Foreclosure Agreement with BB&T in December 2008. On May 12, 2009, the County recorded a boundary line adjustment, consolidating Lots 18 and 19 into Lot 18-A. The recorded boundary line adjustment was not introduced into evidence; however, it appears that both parties agree that the County consolidated the two lots.

Prior to the purchase of Lots 18 and 19, the County did not notify the residents of Little River Farms that it was seeking to acquire the property for a fire and rescue station and did not place any signs on the property indicating its intended use. Upon learning of the planned use for the property, the plaintiffs became concerned and upset. Plaintiffs thereafter filed the instant lawsuit asking the Court to declare that the Developer intended a general scheme of development to restrict the subdivision for residential use only and to be subject to the Covenants; that all lots in the subdivision are restricted to single family use and subject to the Covenants; that the County be enjoined from using Lot 18A for non-residential single family purposes consistent with the Covenants; and that the Covenants be recorded on the land records of the County against each of the lots in the subdivision.

A party seeking to enforce a restrictive covenant bears the burden of establishing the validity and meaning of the covenant and must show that the alleged violations are within the terms of the restrictive covenants. Perel v. Brannan, 267 Va. 691, 700, 594 S.E.2d 899 (2004) (citations omitted); see also Mid-State Equip. Co. v. Bell, 217 Va. 133, 140, 225 S.E.2d 877 (1976) (citations omitted). Covenants restricting the free use of land are not favored and are to be interpreted most strictly against the party seeking to enforce them. Id. Any ambiguity is to be decided against restrictions. Scott v. Walker, 274 Va. 209, 213, 645 S.E.2d 278 (2007) (quoting Schwarzschild v. Welborne, 186 Va. 1052, 1058, 45 S.E.2d 152 (1947)).

Virginia recognizes two types of restrictive covenants: “the common law doctrine of covenants running with the land and restrictive covenants in equity known as equitable easements and equitable servitudes.” Sloan v. Johnson, 254 Va. 271, 274-75, 491 S.E.2d 725 (1997) (citations omitted). The doctrine of restrictive covenants in equity provides that:

[Wjhen, on a transfer of land, there is a covenant or even an informal contract or understanding that certain restrictions in the use of the land conveyed shall be observed, the restrictions will be enforced by equity, at the suit of the party or parties intended to be benefited thereby, against any subsequent [18]*18owner of the land except a purchaser for value without notice of the agreement.

Cheatham v.

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Related

Scott v. Walker
645 S.E.2d 278 (Supreme Court of Virginia, 2007)
Perel v. Brannan
594 S.E.2d 899 (Supreme Court of Virginia, 2004)
Sloan v. Johnson
491 S.E.2d 725 (Supreme Court of Virginia, 1997)
Minner v. City of Lynchburg
129 S.E.2d 673 (Supreme Court of Virginia, 1963)
Mid-State Equipment Co. v. Bell
225 S.E.2d 877 (Supreme Court of Virginia, 1976)
Chavis v. Gibbs
94 S.E.2d 195 (Supreme Court of Virginia, 1956)
Burns v. Winchester Memorial Hospital
303 S.E.2d 908 (Supreme Court of Virginia, 1983)
Cheatham v. Taylor
138 S.E. 545 (Supreme Court of Virginia, 1927)
Schwarzschild v. Welborne
45 S.E.2d 152 (Supreme Court of Virginia, 1947)

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Bluebook (online)
85 Va. Cir. 15, 2011 WL 11521153, 2011 Va. Cir. LEXIS 267, Counsel Stack Legal Research, https://law.counselstack.com/opinion/oliver-v-loudoun-county-board-of-supervisors-vaccloudoun-2011.