POLO GOLF AND COUNTRY CLUB HOMEOWNERS ASSOCIATION, INC. v. CUNARD

854 S.E.2d 732, 310 Ga. 804
CourtSupreme Court of Georgia
DecidedFebruary 15, 2021
DocketS20A1205
StatusPublished
Cited by1 cases

This text of 854 S.E.2d 732 (POLO GOLF AND COUNTRY CLUB HOMEOWNERS ASSOCIATION, INC. v. CUNARD) is published on Counsel Stack Legal Research, covering Supreme Court of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
POLO GOLF AND COUNTRY CLUB HOMEOWNERS ASSOCIATION, INC. v. CUNARD, 854 S.E.2d 732, 310 Ga. 804 (Ga. 2021).

Opinion

310 Ga. 804 FINAL COPY

S20A1205. POLO GOLF AND COUNTRY CLUB HOMEOWNERS ASSOCIATION, INC. v. CUNARD et al.

WARREN, Justice.

The heart of this case is a dispute between the Polo Golf and

Country Club Homeowners’ Association (the “HOA”) and Forsyth

County over the validity of Section 4.2.2 of Forsyth County’s

Addendum to the Georgia Stormwater Management Manual, an

ordinance that makes HOAs “responsible for maintenance of all

drainage easements and all stormwater facilities within the entire

development.” Section 4.2.2 of the Forsyth County Addendum to the

Georgia Stormwater Management Manual (“Section 4.2.2” of the

“Addendum”).1 The HOA argues that Section 4.2.2 is

1 The Addendum was initially promulgated by the County’s Department

of Engineering, but its enabling ordinance incorporates the provisions of the Addendum into the ordinance by reference. See Forsyth County Ordinance No. 75, § 34-184 (c) (“The provisions of the GSMM and the Forsyth County Addendum are incorporated by reference as a part of this Ordinance as fully and completely as if set forth verbatim herein.”). unconstitutional and otherwise invalid and that individual lot

owners are responsible for maintaining stormwater infrastructure

on their lots. Variants of this case have been litigated and appealed

multiple times in this and other Georgia courts, including a 2019

appeal in this Court. See Polo Golf and Country Club Homeowners

Assn., Inc. v. Cunard, 306 Ga. 788 (833 SE2d 505) (2019) (“Polo Golf

II”).2

On remand from our Polo Golf II decision, the trial court

evaluated and rejected the HOA’s remaining claims that Section

4.2.2 is invalid because it requires the HOA to trespass on the

private property of homeowners, constitutes involuntary servitude

2 Polo Golf I, discussed more below, refers to Polo Golf and Country Club

Homeowners’ Assn., Inc. v. Rymer, 294 Ga. 489 (754 SE2d 42) (2014), which involved a dispute between the HOA, Forsyth County, and lot owners within the Polo Golf development over responsibility for a sinkhole on the lot owners’ property. In Polo Golf I, we held that an earlier version of Section 4.2.2, which applied only to a “new development” or “redevelopment,” did not apply to Polo Golf and Country Club, which was developed before the County adopted the Addendum. See Polo Golf I, 294 Ga. at 494-495. On remand, the trial court granted the HOA’s motion for summary judgment as to all of the lot owners’ claims against the HOA. The Court of Appeals affirmed the judgment in part and reversed in part in Rymer v. Polo Golf and Country Club Homeowners Assn., Inc., 335 Ga. App. 167 (780 SE2d 95) (2015). As explained below, the Addendum was revised in 2014. 2 under the United States and Georgia Constitutions, and exceeds the

scope of the ordinance that authorizes Forsyth County to

promulgate the Addendum. The trial court thus denied the HOA’s

motion for summary judgment and granted the defendants’ cross-

motion for summary judgment. The HOA appealed, and we now

affirm.

1. Background.

(a) Litigation History.

In Polo Golf II, we summarized the following background facts:

[The HOA] is a nonprofit corporation which oversees a housing subdivision in unincorporated Forsyth County called “the Polo Fields.”[3] The stormwater mechanisms in the subdivision including the Wellington Dam, which shores up a body of water known as the Wellington Lake, are failing due to age. The failure of these various stormwater mechanisms has caused flooding, sinkholes, and other property damage for some individual homeowners. This situation has resulted in almost a decade’s worth of litigation, including a previous decision in this Court concerning similar underlying facts and some of the same parties. See Polo Golf and Country Club Homeowners’ Assn., Inc. v. Rymer, 294 Ga. 489 (754 SE2d 42) (2014) (“Polo Golf I”). In Polo Golf I, John and Diane Rymer, who were individual homeowners of the Polo

3 At some point before 1995, the neighborhood became known as Polo

Golf and Country Club. 3 Fields, [the HOA], and Forsyth County disagreed as to who was responsible for repairing failing stormwater mechanisms affecting the Rymers’ property pursuant to the 2004 version of Section 4.2.2 set forth in Forsyth County’s Addendum to the Georgia Stormwater Management Design Manual. . . .[4] In Polo Golf I, [the HOA] contended the 2004 version of Section 4.2.2 was unconstitutional; however, this Court did not reach the constitutional issue in Polo Golf I because we concluded that the provision applied to new developments and redevelopments, but not to already-existing developments such as the Polo Fields. 294 Ga. at 495. In January 2014, while this Court’s decision in Polo Golf I was still pending, Forsyth County enacted a new version of Section 4.2.2 which now states in pertinent part as follows: When any subdivision or industrial/commercial park, whether new or existing, has a legally created property or homeowners association, the association will be responsible for maintenance of all drainage easements and all stormwater facilities within the entire development. (Emphasis supplied.)

Polo Golf II, 306 Ga. at 789-790 (footnotes omitted). With

respect to Section 4.2.2, we concluded:

The 2014 version of Section 4.2.2 states that homeowner associations (“HOAs”) are responsible for maintaining all

4 The 2004 version of Section 4.2.2 stated:

When a subdivision or industrial/commercial park has a legally created property or homeowners association, the association will be responsible for maintenance of all drainage easements and all stormwater facilities within the entire development. . . . 4 drainage easements and stormwater facilities in their developments. The 2014 version of Section 4.2.2 further provides that the county, in certain circumstances, may direct HOAs to take certain actions (e.g., applying larvicides or making repairs) to comply with their overall responsibility to maintain such systems or otherwise be penalized for noncompliance.

Id. at 792.

With respect to the repairs at issue here, the following facts are

also relevant. In August 2017, the HOA’s board sent a letter to the

owners of lots at or abutting Wellington Dam and Lake informing

them that the dam was leaking and “could potentially have a

complete failure.”5 Claiming that Polo Golf’s Declaration of

Covenants, Restrictions and Easements (the “Declaration”) “does

not place any obligation upon the [HOA] to maintain or repair the

dam,” the HOA contended that the lot owners were obligated to

maintain and repair all “structures” on their lots under Section 6.14

of the Declaration and that they were obligated to pay the

reasonable expenses necessary to maintain the structural integrity

5 The record shows that the HOA does not own any of the Wellington

Dam/Lake lots. 5 of the dam under Section 6.17 (d). The HOA therefore argued that

the lot owners were obligated to pay for repair of the dam. But it

also gave the lot owners formal notice that “[i]f the dam is not

repaired within thirty days, then the [HOA] may exercise the right

of abatement.”

The lot owners disagreed with the HOA’s characterizations of

their obligations under the Declaration and disputed that they were

obligated to repair the failing dam. Then, in November 2017, the

HOA sent a letter to the lot owners disavowing any involvement

with the repairs and “fully revok[ing]” the portion of its earlier letter

notifying lot owners that it might exercise its right of abatement,

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Bluebook (online)
854 S.E.2d 732, 310 Ga. 804, Counsel Stack Legal Research, https://law.counselstack.com/opinion/polo-golf-and-country-club-homeowners-association-inc-v-cunard-ga-2021.