RCC WESLEY CHAPEL CROSSING, LLC v. ALLEN

867 S.E.2d 108, 313 Ga. 69
CourtSupreme Court of Georgia
DecidedDecember 14, 2021
DocketS21G0029
StatusPublished
Cited by4 cases

This text of 867 S.E.2d 108 (RCC WESLEY CHAPEL CROSSING, LLC v. ALLEN) 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
RCC WESLEY CHAPEL CROSSING, LLC v. ALLEN, 867 S.E.2d 108, 313 Ga. 69 (Ga. 2021).

Opinion

313 Ga. 69 FINAL COPY

S21G0029. RCC WESLEY CHAPEL CROSSING, LLC et al. v. ALLEN et al.

LAGRUA, Justice.

We granted certiorari in this case to decide whether there is a

common-law right that permits private property owners to

immobilize vehicles that are not authorized to be on their property.

For the reasons that follow, we conclude that the common-law rights

the defendants alluded to in the courts below — namely, the right to

remove trespassing vehicles and an alleged right to impound

trespassing vehicles — do not apply to the defendants’ vehicle

immobilization practice. However, because we disagree with the

Court of Appeals’ conclusion that “the trial court did not err in

finding no common law right to immobilize a vehicle absent an

enabling statute or ordinance,” RCC Wesley Chapel Crossing v.

Allen, 355 Ga. App. XXVII (Case No. A20A0547) (June 29, 2020)

(unpublished), and any reliance on that conclusion in affirming the

1 trial court’s order granting Plaintiff Forrest Allen’s motion for class

certification, see slip op. at 10-15, we vacate the judgment of the

Court of Appeals and remand the case to the Court of Appeals with

direction to remand to the trial court for reconsideration of the

proposed class.

1. Pertinent facts and procedural history.

(a) Factual background.

The relevant facts, as summarized by the Court of Appeals, see

Allen, slip op. at 4-5, are as follows: On February 5, 2018, Plaintiff

parked his vehicle in a parking lot located at 2440 Wesley Chapel

Road (the “Wesley Chapel Lot”) in DeKalb County, and nonparty

State Impound Authority, LLC d/b/a VPE LLC (“State Impound”)

immobilized Plaintiff’s vehicle by placing a “boot” on one of the tires.

In order to remove the boot, Plaintiff was required to pay State

Impound $650. Plaintiff paid State Impound the requisite fee to

remove the boot from his vehicle.

(b) Trial court proceedings.

In February 2018, Plaintiff filed a lawsuit in the State Court of

2 Clayton County on behalf of himself and a putative class of similarly

situated persons against Defendants RCC Wesley Chapel Crossing,

LLC, Little Giant Farmers Market Corporation, Dollar Tree Stores,

Inc., River City Capital, LLC, and River City Capital Property

Management, LLC1 for negligence, premises liability, false

imprisonment, conversion, and violation of the Georgia Racketeer

Influenced and Corrupt Organizations Act. Plaintiff claimed that

Defendants “hired, authorized, or otherwise provided material

support to” third parties that immobilized vehicles located on

Defendants’ property with boots or similar devices and required the

owners or operators of the vehicles to pay a fee in order to have the

immobilizing devices removed. Plaintiff moved to certify the action

on behalf of a proposed class of similarly situated persons under

OCGA § 9-11-23,2 asserting that between February 2013 and the

1 The record reflects that Defendants consist of the owner and operator

of the Wesley Chapel Lot and the commercial tenants of the adjacent shopping center.

2 Pursuant to OCGA § 9-11-23 (a):

One or more members of a class may sue or be sued as representative parties on behalf of all only if: 3 present, at least 250 persons “have been booted, and have paid a fine

for removal of said device” at the Wesley Chapel Lot. Following

briefing and oral argument, the trial court granted Plaintiff’s

motion, certifying the following class: “A class of all persons who

have been booted, and have paid a fine for removal of said device, at

2440 Wesley Chapel Rd. (Parcel ID 15 131 03 010) or 2460 Wesley

Chapel Rd. (Parcel ID 15 130 02 110) from February 5, 2013,

through present.”

In the order granting class certification, the trial court

reasoned that “[t]he act of placing a boot on a vehicle and refusing

to remove it until payment is received is the imposition of a lien on

that vehicle,” and “[s]uch a lien cannot exist at common law as lien

laws are in derogation of the common law.” On this basis, the trial

court concluded that

(1) The class is so numerous that joinder of all members is impracticable; (2) There are questions of law or fact common to the class; (3) The claims or defenses of the representative parties are typical of the claims or defenses of the class; and (4) The representative parties will fairly and adequately protect the interests of the class.

4 Defendants cannot immobilize vehicles, or demand a fee to remove a vehicle immobilization device, absent an enabling statute. . . . There is no enabling statute or ordinance at the location where Plaintiff and all other class members were booted.

The trial court thus determined that each of the class member’s

claims involved the common question of whether Defendants had “a

legal right to immobilize vehicles at the subject properties” — a

question that did not depend on “individualized issues of fact” or the

class members’ “legal status at the property.”

Defendants appealed, asserting that the trial court erred in

granting class certification because Plaintiff failed to meet all the

requirements of OCGA § 9-11-23 (a). In particular, citing Reinertsen

v. Porter, 242 Ga. 624 (250 SE2d 475) (1978), Defendants asserted

that the trial court erred in determining that there was commonality

among the putative class because some of the potential class

members were trespassers on the Wesley Chapel Lot and

Defendants have a common-law right to immobilize trespassing

vehicles on their property.

(c) The Court of Appeals’ decision.

5 In June 2020, the Court of Appeals affirmed the trial court,

holding, among other things, that (1) the trial court did not err in

concluding that there is no right to immobilize a vehicle absent an

enabling statute or ordinance; and (2) the trial court properly found

that liability could be determined solely by looking to Defendants’

conduct because, even if some class members were parked on the

Wesley Chapel Lot without authorization, there was no showing in

the record that the immobilization of the class members’ vehicles or

the process for releasing immobilized vehicles back to their owners

differed materially. See Allen, slip op. at 8-10. In so holding, the

Court of Appeals rejected Defendants’ reliance on Reinertsen, noting

that, although Reinertsen recognized a landowner’s right at common

law to remove with due care the property of others left on his land

without permission, “nothing in the Supreme Court’s opinion

recognizes a common law right to place immobilizing devices on

vehicles illegally parked on private property against the will of its

owner for profit.” Allen, slip op. at 12 n.1.

We granted Defendants’ petition for certiorari to address

6 whether a common-law right exists allowing a private property

owner to immobilize a vehicle parked on its property without

permission.

2. There is no common-law right allowing private property

owners to immobilize unauthorized vehicles parked on their property.

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Bluebook (online)
867 S.E.2d 108, 313 Ga. 69, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rcc-wesley-chapel-crossing-llc-v-allen-ga-2021.