Stella Maris Condominium Association, Inc. v. David Trautenberg

CourtLouisiana Court of Appeal
DecidedApril 12, 2023
Docket2022-CA-0696
StatusPublished

This text of Stella Maris Condominium Association, Inc. v. David Trautenberg (Stella Maris Condominium Association, Inc. v. David Trautenberg) is published on Counsel Stack Legal Research, covering Louisiana Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Stella Maris Condominium Association, Inc. v. David Trautenberg, (La. Ct. App. 2023).

Opinion

STELLA MARIS * NO. 2022-CA-0696 CONDOMINIUM ASSOCIATION, INC. * COURT OF APPEAL VERSUS * FOURTH CIRCUIT DAVID TRAUTENBERG * STATE OF LOUISIANA *******

APPEAL FROM CIVIL DISTRICT COURT, ORLEANS PARISH NO. 2020-09686, DIVISION “D” Honorable Nakisha Ervin-Knott, Judge ****** Judge Roland L. Belsome ****** (Court composed of Judge Roland L. Belsome, Judge Daniel L. Dysart, Judge Rachael D. Johnson)

Elizabeth A. Roussel Erica P. Sensenbrenner ADAMS AND REESE LLP 701 Poydras Street Suite 4500 New Orleans, LA 70139

COUNSEL FOR PLAINTIFF/APPELLEE

Justin E. Alsterberg JJC Law, LLC 3914 Canal Street New Orleans, LA 70119

COUNSEL FOR DEFENDANT/APPELLANT

AFFIRMED APRIL 12, 2023 RLB This case involves a dispute between a condominium unit owner and the DLD RDJ condominium association. Appellant David Trautenberg appeals from the trial

court’s June 30, 2022, judgment, which granted Appellee Stella Maris

Condominium Association, Inc.’s motion for summary judgment and denied in

part Trautenberg’s motion for partial summary judgment. The effect of the

judgment was to dismiss both parties’ claims against each other. For the reasons

that follow, this Court affirms.

FACTUAL BACKGROUND AND PROCEDURAL HISTORY

The Stella Maris Condominiums (“the Condominiums”) are situated in the

New Orleans French Quarter. In 1995, the Stella Maris Condominium Property

Regime was created through a Declaration executed and recorded by the owner

(“the Declaration”). Additionally, the Stella Maris Condominium Association, Inc.

(“the Association”) was incorporated as a Louisiana non-profit corporation which,

through its board of directors, is the governing body of the Condominiums.

1 In 2018, Trautenberg purchased Unit 7 of the Condominiums, a three-story

unit. The ground floor of Unit 7 also opens onto a private patio situated in the

interior courtyard of the Condominium, accessible only through Unit 7 and

partitioned from the courtyard by a wooden fence. Unit 7’s second floor has two

sets of French doors set into its exterior wall, overlooking the Condominium’s

courtyard. This feature has been described by the parties as a “Juliet balcony”.1

The third floor of Unit 7 contains its master bedroom and bathroom, and also

provides access to a private rooftop deck accessible only by the owner of Unit 7.

Trautenberg performed substantial renovations to Unit 7 before moving in.

During the course of those renovations, Trautenberg discovered damage to the wall

separating Unit 7 from the courtyard of the building, which the Association spent

approximately $35,000 to repair. Trautenberg also replaced the second floor

French doors (forming part of the Juliet balcony) with “marine grade” doors, the

cost for which was reimbursed by the Association. Finally, Trautenberg also

requested the Association’s permission to replace the ground-floor doors providing

access to his private patio, and to install a retractable awning above the patio. The

Association acceded to Trautenberg’s first request, but denied him permission to

install a retractable awning.

In early 2019, the Association decided to replace an awning which spanned

the exterior wall separating Units 7 and 8 from the courtyard. The Association took

1 A “Juliet balcony” is actually no balcony at all, but rather refers to an elevated French door

which is inset with a protective barrier (typically to waist-height), allowing the occupant to open the French door without fear of accidentally falling to the ground below. Thus, a Juliet balcony by definition does not include what is traditionally thought of as a “balcony” (an area that can be physically entered and walked upon).

2 this action in response to water intrusion and damage to that wall, which the

Association had paid to repair, including: the $35,000 spent during Trautenberg’s

renovations to Unit 7, the replacement of Trautenberg’s second-story French doors,

and $20,000 spent to repair the exterior wall of Unit 8 (which occurred prior to

Trautenberg’s arrival). Notably, the expense for the replacement awning was not

included in the Association’s annual budget, and was not put to a vote of the unit

owners.

Over the objections of Trautenberg, the replacement awning was erected on

or around February 14, 2020. The replacement awning was larger than the awning

previously in place. Trautenberg alleges that, as a result, his patio and second-story

French doors (the Juliet balcony) receive less sunlight. To remedy this offense and

“reclaim his sunlight”, Trautenberg decided that he would like to construct a true

balcony (one that could be entered through his second-story French doors and

walked upon, see footnote 1 above), to be attached to the exterior wall of his unit

and over-hanging his ground-floor private patio and a portion of the Condominium

courtyard.

Trautenberg began working with an architect to design the new balcony, and

on April 27, 2020, submitted his plans, along with a request for permission, to the

Association’s board of directors. On May 1, 2020, the board unanimously denied

Trautenberg’s request. In the Association’s letter to Trautenberg informing him of

the decision, the Association explained that the reasons for its denial were sound

and privacy concerns. Specifically, the Association informed Trautenberg that

3 unlike the Condominium’s private patios, which are enclosed by a wooden fence,

Trautenberg’s proposed balcony would not include a sound barrier between it and

the Condominium’s courtyard and other units. Second, the Association explained

that the proposed balcony would disrupt the privacy of other units and encroach

onto the Condominium’s common area (the interior courtyard). Finally, the

Association noted that Unit 7 already enjoyed the use of a private rooftop terrace.

In response to the Association’s denial, Trautenberg redesigned his proposed

balcony so that it would overhang only his own private ground-floor patio.

However, rather than submitting this new design to the Association, Trautenberg

submitted an application to the Vieux Carré Commission (“VCC”) for a permit

regarding his proposed balcony, submitted on May 18, 2020. The VCC’s

Architectural Committee set the matter for a public meeting to be held June 9,

2020.

The day before the Architectural Committee’s meeting, the Association’s

president, David Bryan, learned of Trautenberg’s pending permit application and

informed the rest of the Association’s board of directors. Later that day Bryan sent

a letter to the VCC on behalf of the Association, informing it that Trautenberg did

not have the Association’s approval to build the balcony and requesting the matter

be removed from the VCC’s meeting agenda. The VCC’s Senior Building Plans

Examiner, Nicholas Albrecht, responded that the permit would be removed from

the agenda and would only be considered in the future if Trautenberg could

demonstrate the Association’s approval.

4 The following day, June 9, 2020, Trautenberg corresponded with the

Director of the VCC, Bryan Block, complaining that the Association lacked legal

standing to block his permit application process as they were not party to it, and

asking the VCC to disregard future communications from the Association. After

consulting with the City’s legal department, Director Block advised Trautenberg

that “[i]f there are issues between you and your HOA, this will be a civil matter for

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Stella Maris Condominium Association, Inc. v. David Trautenberg, Counsel Stack Legal Research, https://law.counselstack.com/opinion/stella-maris-condominium-association-inc-v-david-trautenberg-lactapp-2023.