Simmons v. On Faith, L.L.C.

69 Va. Cir. 355, 2005 Va. Cir. LEXIS 193
CourtBotetourt County Circuit Court
DecidedDecember 8, 2005
StatusPublished

This text of 69 Va. Cir. 355 (Simmons v. On Faith, L.L.C.) is published on Counsel Stack Legal Research, covering Botetourt County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Simmons v. On Faith, L.L.C., 69 Va. Cir. 355, 2005 Va. Cir. LEXIS 193 (Va. Super. Ct. 2005).

Opinion

By Judge Humes J. Franklin, Jr.

After consideration of this matter, it is the judgment of this Court that the restrictive covenants are not enforceable against the tract of land owned by the Respondent, On Faith, L.L.C. The restrictions the Complainants seek to enforce are not within On Faith’s chain of title. The restrictive covenants being outside the chain of title, they are not enforceable because horizontal and/or vertical privity is lacking. Additionally, the Complainants do not posses an equitable right to enforce an implied negative reciprocal easement because the prohibition of commercial use of Tract 1 was not part of the common grantor’s general plan or scheme. The evidence supporting the restriction is ambiguous and must be resolved in favor of the free use of the land. Therefore, the Court denies all relief sought by the Complainants’ Bill of Complaint for Declaratory Judgment, grants the Respondent’s Cross-Bill, and declares that Tract 1 is not restricted to residential purposes and the Respondent, is not prohibited from developing Tract 1 for commercial purposes.

I. The restrictive covenants, including the prohibition on commercial use of the property, are not within the chain of title to On Faith’s property, the parcel of land designated “Tract 1” on the British Woods subdivision plat.

[356]*356Property conveyed under a deed of trust which predated the creation of restrictions on that property is not encumbered by those restrictions. Marbury v. Jones, 112 Va. 389, 395-96, 71 S.E. 1124, 1127 (1911); Nagle v. Syer, 150 Va. 508, 512, 143 S.E. 690, 691 (1928). Although the restrictions in those cases were a mortgage and a lease, respectively, and this case involves a restrictive covenant, the rule followed in those cases applies here. An agreement made between the grantor and a third party “after he has given the deed of trust, [can]not in any way affect the rights of the trustee or his purchaser.” Id. at 395, 71 S.E. at 1126. Court opinions from other jurisdictions also provide persuasive authority for this proposition. Carden v. Bush, 155 S.E. 914, 915 (W. Va. 1930); Vernon v. Allphin, 98 So. 2d 280, 284 (La. App. 1957); St. Louis Union Trust Co. v. Foster, 190 S.E. 522, 530 (N.C. 1937).

James Long executed a deed of trust in 1972, which granted a lien on the real property in British Woods, including Tract 1. The restrictive covenants were created in 1973. The deed of trust was foreclosed in 1975, and that the property, including Tract 1, was conveyed to F irst Union National Bank of North Caroline by the foreclosure trustee. On Faith traces its chain of title to the foreclosure trustee.

Applying the precedent cited above, the covenants do not exist in On Faith’s chain of title because they were created after the entry of the deed of trust. As in Marbury, an agreement between a grantor and a third party after the grantor has given a deed of trust cannot affect the rights of the trustee or those who purchase from the trustee. The trustee and the subsequent owners of Tract 1 never gave consent to the creation of restrictive covenants.

The covenants were not reimposed or reincorporated into the title to Tract 1 by language in subsequent deeds that stated that “this conveyance is made subject however to all easements, restrictions, and covenants of record that effect the property hereinabove described.” This phrase serves to qualify and give notice; it does not imply assumption of all previously created restrictions. S. L. Nusbaum v. Atlantic Virginia Realty Corp., 206 Va. 673, 679, 146 S.E.2d 205, 209 (1966). Such language does not impose any new restrictions. See Taylor v. McConchrie, 264 Va. 377, 383, 569 S.E.2d 35, 38 (2002).

H. Because the restrictive covenants axe not within On Faith’s chain of title, they are not enforceable against On Faith. In Virginia, “[a] restrictive covenant is enforceable if a landowner establishes: (1) horizontal privity; (2) vertical privity; (3) intent for the restriction to run with the land; (4) that the restriction touches and concerns the land; and (5) that the covenant is in writing.” Barner v. Chappell, 266 Va. 277, 283, 585 S.E.2d 590, 594 (2003).

“In order to establish horizontal privity, the party seeking to enforce the real covenant must prove that ‘the original covenanting parties [made] their [357]*357covenant in connection with the conveyance of an estate in land from one of the parties to the other’." Sonoma Dev., Inc. v. Miller, 258 Va. 163, 168, 515 S.E.2d 577, 580 (1999) (quoting Runyon v. Paley, 416 S.E.2d 177, 184 (N.C. 1992)). “In other words, the covenant must be part of a transaction that also includes the transfer of an interest in land that is either benefited or burdened by the covenant.” Id.

The deed in this case was not made “in connection with the conveyance of an estate in land” from one party to another. James Long is the sole signatory of the deed, and the only party who was involved in creating the restriction. Deed No. 73-1603, Deed Book 210, Page 4, of Botetourt County, Virginia (August 27, 1973). These facts fail to meet the requirement that that the covenant be part of a transaction or conveyance.

Although the lack of horizontal privity alone is enough to support the Court’s finding that the restrictive covenants are not enforceable, the Court also finds that vertical privity is lacking here. “Vertical privity exists when there is privity between the original parties and their successors-in-interest.” Id. The parties seeking to enforce a restrictive covenant must trace their title directly to the beneficiary of the restrictive covenant. Id.

The title held by Complainants Mr. and Mrs. Chrimes, Lee, and Reynolds is traceable to property which was released from the deed of trust before it was foreclosed. Thus, those Complainants are in privity with the original beneficiaries of the restrictive covenant. However, the titles belonging to the remainder of the Complainants and On Faith trace back to the 1972 deed in trust. There is no privity between On Faith and the original parties to the covenant, and, therefore, vertical privity does not exist here, rendering the covenant unenforceable.

HI. As an alternative to their claim seeking to enforce a common law covenant running with the land, the Complainants seek the imposition of a restrictive covenant in equity, known as an equitable easement, equitable servitude, or an implied reciprocal negative easement.

The doctrine of restrictive covenants in equity provides that “an equitable servitude can only arise when a common grantor imposes a common restriction upon land developed for sale in lots.” Barner, 266 Va. at 285, 585 S.E.2d at 595. The party claiming the benefit of an equitable servitude has the burden of showing that a common restriction was intended. Id. at 286, 585 S.E.2d at 595. “The intent of the parties, especially that of the common grantor, determines the existence of the right.”

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Related

Barris v. Keswick Homes, LLC
597 S.E.2d 54 (Supreme Court of Virginia, 2004)
Barner v. Chappell
585 S.E.2d 590 (Supreme Court of Virginia, 2003)
Taylor v. McConchie
569 S.E.2d 35 (Supreme Court of Virginia, 2002)
Sonoma Development, Inc. v. Miller
515 S.E.2d 577 (Supreme Court of Virginia, 1999)
Anderson v. Lake Arrowhead Civic Ass'n
483 S.E.2d 209 (Supreme Court of Virginia, 1997)
Minner v. City of Lynchburg
129 S.E.2d 673 (Supreme Court of Virginia, 1963)
Marriott Corp. v. Combined Properties Ltd. Partnership
391 S.E.2d 313 (Supreme Court of Virginia, 1990)
Runyon v. Paley
416 S.E.2d 177 (Supreme Court of North Carolina, 1992)
Mid-State Equipment Co. v. Bell
225 S.E.2d 877 (Supreme Court of Virginia, 1976)
S. L. Nusbaum & Co. v. Atlantic Virginia Realty Corp.
146 S.E.2d 205 (Supreme Court of Virginia, 1966)
Friedberg v. Riverpoint Building Committee
239 S.E.2d 106 (Supreme Court of Virginia, 1977)
St. Louis Union Trust Co. v. Foster
190 S.E. 522 (Supreme Court of North Carolina, 1937)
Carden v. Bush
155 S.E. 914 (West Virginia Supreme Court, 1930)
Marbury v. Jones
71 S.E. 1124 (Supreme Court of Virginia, 1911)
Whitehurst v. Burgess
107 S.E. 630 (Supreme Court of Virginia, 1921)
Nagle v. Syer
143 S.E. 690 (Supreme Court of Virginia, 1928)
Vernon v. Allphin
98 So. 2d 280 (Louisiana Court of Appeal, 1957)

Cite This Page — Counsel Stack

Bluebook (online)
69 Va. Cir. 355, 2005 Va. Cir. LEXIS 193, Counsel Stack Legal Research, https://law.counselstack.com/opinion/simmons-v-on-faith-llc-vaccbotetourt-2005.