Scott v. Fall Line Condominium Association

CourtSuperior Court of Maine
DecidedOctober 4, 2018
DocketCUMbcd-cv-17-26
StatusUnpublished

This text of Scott v. Fall Line Condominium Association (Scott v. Fall Line Condominium Association) is published on Counsel Stack Legal Research, covering Superior Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Scott v. Fall Line Condominium Association, (Me. Super. Ct. 2018).

Opinion

STATE OF MAINE BUSINESS & CONSUMER DOCKET CUMBERLAND, ss. DOCKET NO. BCDWB-CV-2017-26

KIMBERLY B. SCOTT, et al., ) ) Plaintiff, ) ) ORDER DETERMINING WHICH v. ) CONDOMINIUM ASSOCIATION ) RULES AND REGULATIONS FALL LINE CONDOMINIUM ) REQUIRE APPROVAL BY A ASSOCIATION ) MAJORITY IN INTEREST OF UNIT ) OWNERS Defendant, )

The issue before the Court, on remand from the Law Court, is which Fall Line

Condominium Association rules and regulations require approval by a majority in interest of

Unit Owners under section 5.17 of the Association Bylaws.1 On appeal from a declaratory

judgment issued by this court, the Law Court determined that section 5.17 unambiguously limits

the Board’s broad authority under section 2.03(e) to adopt and amend rules. Scott v. Fall Line

Condo. Ass’n, 2019 ME 50, ¶ 10, 206 A.3d 307. According to section 5.17, the Board of

Directors must seek approval from a majority in interest of Unit Owners when promulgating or

amending rules of conduct that concern the use of the units, common areas, and facilities. Scott v.

Fall Line Condo. Ass’n., 2019 ME 50, ¶ 13. The Law Court left to this Court the task of

determining “what constitutes a rule of conduct that dictates the use of the units, common areas,

or facilities.” Scott v. Fall Line Condo. Ass’n., 2019 ME 50, ¶ 13. As discussed below, the Court

1 On remand, the parties agreed an evidentiary hearing was unnecessary, and submitted the issue to the Court on briefs.

1 concludes that most, but not all, of the Association’s rules still in dispute are void because they

constitute rules of conduct which require majority in interest approval pursuant to section 5.17.

DISCUSSION

As the Law Court noted in its decision, condominium association’s bylaws and

declarations are contracts, Scott v. Fall Line Condo. Ass’n., 2019 ME 50, ¶ 6, and thus must be

“construed in accordance with the intention of the parties, which is to be ascertained from an

examination of the whole instrument. All parts and clauses must be considered together [so] that

it may be seen if and how one clause is explained, modified, limited or controlled by the others.”

Scott v. Fall Line Condo. Ass’n., 2019 ME 50, ¶ 7, (quoting Am. Prat. Ins. Co. v. Acadia Ins.

Co., 2003 ME 6, ¶ 11, 814 A.2d 989 (quotation marks omitted). Generally, the court will not

interpret a contract in a manner that would render meaningless any particular provision.

Farrington’s Owners’ Assn., v. Conway Lake Resorts, Inc., 2005 ME 93, ¶ 10, 878 A.2d 504.

The language must be construed to give effect to the plain meaning of the words used. Scott v.

Fall Line Condo. Ass’n., 2019 ME 50, ¶ 8. (quoting City of Augusta v. Quirion, 436 A.2d 388,

392 (Me. 1981). In this case, what constitutes a rule of conduct concerning the use of the Units,

Common Areas, and facilities, can be readily determined by the context and plain language of

sections 2.03(e) and 5.17 of the Bylaws.

Section 2.03(e) authorizes the Board to adopt rules, without approval from a majority in

interest of Unit Owners, “covering the details of the operation and use of the Property.” The term

“Property” is broadly defined in section 1.02 to encompass the land, buildings, improvements,

easements, appurtenances, Units, Common Elements, and all other property, personal or mixed,

comprising the Fall Line Condominium. 2 Section 2.03(e) is situated within section 2.03, which

2 Definitions for Unit and Common Elements are supplied in the Declaration and in the Maine Condominium Act, 33 M.R.S. § 1601-103.

2 enumerates the powers and duties of the Board. The Board’s powers and duties generally include

governance, maintenance of Common Areas, financial management, and administration. Section

2.03 is in turn embedded within Article 2, which is entitled Board of Directors. Article 2

describes the composition and function of the Board generally.

The Law Court determined that section 2.03(e)’s broad grant of authority to the Board to

promulgate rules on its own is cabined by section 5.17. Section 5.17 requires the Board to obtain

the approval of a majority in interest of Unit Owners in order to promulgate rules of conduct

“concerning the use of the Units and the Common Areas and facilities.”

In contrast to section 2.03(e), section 5.17 applies to only a subset of the Condominium’s

Property: Units, and Common Areas and facilities. Section 5.17 therefore has a narrower focus

than does section 2.03(e), which addresses the Property as a whole. Section 5.17 also only

applies to “rules of conduct.” The phrase “conduct” is undefined, but susceptible to a plain

language reading. “Conduct” is commonly defined to mean the manner in which a person

behaves. Conduct, Dictionary.com, (last visited Oct. 2, 2019). “Rules of conduct” therefore mean

rules of behavior. Further, read in the context of Article 5, the behavior at stake is that of Unit

Owners and their guests (including renters). The term “use” is also undefined, but commonly

understood to mean employ for some purpose. Use, Dictionary.com, (last visited Oct. 2. 2019).

Based on its context and plain language, section 5.17 is unambiguous. Any rule concerning the

manner in which Unit Owners and their guests use the Units and the Common Areas and

facilities requires majority in interest approval of the Unit Owners in order to become valid and

enforceable.

Considering the context and plain language of sections 2.03(e) and 5.17, along with the

Law Court’s admonishment that section 5.17 acts as a constraint on the Board’s authority, it is

3 possible to derive a set of guidelines for determining when a rule is subject only to section

2.03(e), or constitutes a rule of conduct requiring majority of interest approval pursuant to

section 5.17:

1. Subject to Guideline 4, below, Rules applying to the Property as a whole can be validly

promulgated by the Board pursuant to section 2.03(e).

2. Subject to Guideline 4, below, Rules applying to Board responsibilities for governance,

maintenance, financial management, or administration can be validly promulgated by the

Board pursuant to section 2.03(e).

3. Rules concerning the manner in which Unit Owners and their guests use the Units and

Common Areas and facilities need majority in interest approval pursuant to section 5.17

in order to be valid and enforceable.

4. Rules that have attributes that could be characterized as subject to only section 2.03(e),

but which also concern the manner in which Unit Owners and their guests use the Units

and the Common Areas and facilities, are subject to 5.17. In other words, in the case of

conflict, dual or multiple purposes, section 5.17 prevails.

5. Rules that add to, provide specific examples for, or qualify provisions in the Bylaws that

regulate the manner in which Unit Owners and their guests use the Units and the

Common Areas and facilities, are subject to section 5.17. For instance, section 5.11(c)

prohibits nuisances on the Property. If a rule is proposed that defines nuisances to include

the use of percussion instruments and prohibits the use of such instruments in Units or the

Common Areas, the rule is subject to section 5.17.

APPLICATION TO RULES AT ISSUE

4 The parties have agreed on the proper disposition of some rules reducing the rules in

dispute.3 Applying the above guidelines to each of the remaining rules in dispute, the court finds

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