Richard M. Breen v. Nolan Leuthauser

CourtCourt of Appeals of Kentucky
DecidedJanuary 3, 2025
Docket2024-CA-0214
StatusUnpublished

This text of Richard M. Breen v. Nolan Leuthauser (Richard M. Breen v. Nolan Leuthauser) is published on Counsel Stack Legal Research, covering Court of Appeals of Kentucky primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Richard M. Breen v. Nolan Leuthauser, (Ky. Ct. App. 2025).

Opinion

RENDERED: JANUARY 3, 2025; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals NO. 2024-CA-0214-MR

RICHARD M. BREEN AND ANN W. BREEN APPELLANTS

APPEAL FROM JEFFERSON CIRCUIT COURT v. HONORABLE BRIAN C. EDWARDS, JUDGE ACTION NO. 22-CI-003759

NOLAN LEUTHAUSER; AMANDA S. DAVENPORT, M.D.; C. BARRET BIRNSTEEL; CITY OF GLENVIEW; HELEN T. SIMON LIVING TRUST; LOURIE BIRNSTEEL; NORA C. SUTHERLAND; ROBERT E. SUTHERLAND, JR.; RYAN A. BURSON; SARAH LEIGHT; THE SARAMMA CHERIAN RESTATED TRUST; AND WESTENHOFER FAMILY REVOCABLE LIVING TRUST APPELLEES

OPINION AFFIRMING

** ** ** ** **

BEFORE: CETRULO, EASTON, AND TAYLOR, JUDGES. EASTON, JUDGE: The Appellants, Richard M. Breen and Ann W. Breen

(collectively “the Breens”), filed a Complaint and Declaratory Judgment Action

against the owners of all properties in their Glen Arden Road neighborhood,

including Appellees Nolan Leuthauser (“Leuthauser”) and Sarah Leight (“Leight”).

The Breens also named the City of Glenview (“the City”) as a party. All the

properties involved are located in the City.

The Breens filed their case in response to a permit application filed by

Leuthauser and Leight to use their property as a short-term rental home or Airbnb.1

The Complaint sought to enjoin such use of the property. The Breens specifically

sought a declaration that Glen Arden Road is a private road. The Breens argue that

the joint easement which comprises a private road may not be overly burdened by

increased Airbnb traffic. The Breens also contend that use as an Airbnb would

violate zoning regulations and subdivision restrictions.

Having at least temporarily abandoned the seeking of a permit,

Leuthauser and Leight filed a Motion to Dismiss the Complaint. The circuit court

dismissed the Complaint in its entirety. We conclude that the circuit court could

1 An abbreviation for “Air Bed and Breakfast.” Less than twenty years ago, the concept of the Airbnb arose in cities with limited or expensive hotel space. The choice of the name is because originally homeowners or apartment renters offered to place an air mattress on the floor and provide access to breakfast foods for a set price. Part of the so-called “sharing economy,” this type of accommodation has become a popular option to replace traditional hotels or similar places to stay for short terms. Why Is It Called Airbnb? The Origin Story and Its Impact Today, AIRDNA, https://www.airdna.co/blog/why-is-it-called-airbnb (last visited Dec. 10, 2024).

-2- not proceed with a moot, unripe controversy and give an advisory opinion. Even if

a proper and present controversy existed, the circuit court did not abuse its

discretion in declining to proceed with the declaratory judgment action. The

Complaint otherwise did not state a cause of action. We affirm.

FACTUAL AND PROCEDURAL HISTORY

Glen Arden Road is a narrow, basically one-lane road with five homes

having access from it. Leight’s grandparents, Dr. Leonard Leight and Adele

Leight, owned the home at 6 Glen Arden Road (the “Leight Property”). After the

death of her grandparents, Leight and her husband Leuthauser purchased the home

in March of 2022.

While Leight’s grandparents owned the property, it had been used as

an exhibition space for contemporary glass art.2 Not needing the home as a

residence for themselves, Leuthauser and Leight considered renting it to small

groups for limited periods. They filed a Short-Term Rental Conditional Use

Permit Pre-Application with Louisville Metro Planning and Design Services. Part

of the process for such permits is to conduct a neighborhood meeting about the

proposed use.

2 This arguably non-residential use apparently was not a problem for the Breens or the other Glen Arden Road neighbors. The details of this use and whether this presents any question of estoppel or waiver as to non-residential use of the Leight property is premature.

-3- Leuthauser and Leight conducted two neighborhood meetings, one in

April and another in June of 2022. After such meetings, an applicant has a limited

period to proceed further with the application process. During this stage of the

process, the Breens filed this suit. Leuthauser and Leight ultimately declined to

file a formal permit application with the Louisville Metro Board of Zoning

Adjustment (“BOZA”) within the 90-day deadline. Thus, that permit application

died.

Clearly, the Breens do not want the issue to arise again. They seek

permanent injunctive relief. The Breens present the Glen Arden Road area as an

historic and exclusive neighborhood, and they want to keep it that way.

The most important word in the Complaint is a short one – if. This

word begins multiple paragraphs3 of the Complaint. The Complaint states a clear

claim only with respect to if the Airbnb permit were to be allowed. While the

Complaint demands damages, it does not say what for. There is no stated claim

that extra expenses for the maintenance of the road have been sustained due to use

as an Airbnb, which has not been permitted. The Complaint does not state any

other damages actually incurred from any other cause.

The Complaint mentions deed restrictions for property on Glen Arden

Road. The Declaration of Restrictions states: “No lot shall be used except for

3 See Complaint, Paragraphs 20, 43, and 45.

-4- private single-family residential purposes.” The same document states: “No trade

or business of any kind . . . shall be conducted on any lot, nor shall anything be

done thereon which may become an annoyance or nuisance to the owner or owners

of other lots.”

The Complaint also mentions the “Glenview Area Neighborhood

Plan” ordinances passed by the Louisville Metro Government. The Glenview Area

Neighborhood Plan limits all multi-family housing to areas already zoned for such

development, limits all non-residential uses to those already in existence, and

limits Glen Arden Road to single-family residences.

The City timely filed its Answer and responded to the Breens’

discovery requests. The City admitted it has not spent any funds to repair, repave,

or maintain Glen Arden Road. The City admitted that its 2022 budget did not

allocate any funds for the maintenance of Glen Arden Road and that it did not

presently maintain Glen Arden Road. The City acknowledged that it had not

“taken any action to dedicate Glen Arden Road to the City of Glenview as a public

road or easement.” A City ordinance4 recognizes the existence of private roads in

the City and creates a process to make them public roads. Nothing in the record

suggests that Glen Arden Road has gone through this process.

4 Ordinance 3, Series 2010, was enacted when Richard Breen was mayor of Glenview.

-5- After abandoning their permit application, Leuthauser and Leight

moved to dismiss the Complaint under CR5 12.02 for lack of subject matter

jurisdiction and for failure to state a claim upon which relief can be granted. Their

motion asserted that no case or controversy was ripe for adjudication because

BOZA had not issued a permit allowing short-term rentals of the Leight Property.

They argued that, since a formal application was not filed with BOZA within the

required 90-day timeframe, there was no present controversy, and the Breens were

asking the circuit court for an improper advisory opinion about potential, future

situations.

While this dispositive motion was pending, the Breens tendered

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