Vt Land Trust v. Kurt

CourtVermont Superior Court
DecidedDecember 16, 2024
Docket23-cv-2766
StatusPublished

This text of Vt Land Trust v. Kurt (Vt Land Trust v. Kurt) is published on Counsel Stack Legal Research, covering Vermont Superior Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Vt Land Trust v. Kurt, (Vt. Ct. App. 2024).

Opinion

7ermont Superior Court Filed 12/13/24 Addison Unit

VERMONT SUPERIOR COURT CIVIL DIVISION Addison Unit Case No. 23-CV-02766 7 Mahady Court

Middlebury VT 05753 802-388-7741 www.vermontjudiciary.org

Vermont Land Trust et al v. Kerry Kurt et al

ENTRY REGARDING MOTION Title: Motion for Summary Judgment; Motion to Dismiss; (Motion: 3; 4) Filer: Justin B. Barnard; Kerry Kurt Filed Date: September 05, 2024; October 14, 2024

This case involves potential violations of a conservation easement held by Vermont Land Trust (VLT), Vermont Housing and Conservation Board (VHCB), and Vermont Agency of Agriculture, Food and Markets (VAAFM) (collectively, "Plaintiffs"). The easement burdens land owned by Kerry Kurt ("Ms. Kurt"), who is a defendant in this action. The other named defendant is Keenan Kurt ("Mr. Kurt'), who is Ms. Kurt's son and also goes by the name "Sovereign-Naan Keenan-Phillip Of-Allodium." Plaintiffs move for summary judgment on their claims that Mr. Kurt's activities (including erection of unauthorized structures) violate the terms of the easement and constitute trespass.

Vermont Rule of Civil Procedure 56(c) (V.R.C.P. 56(c)) sets forth the procedure around responding to motions for summary judgment. To avoid summary judgment, the nonmoving party must "file a paragraph-by-paragraph response, with specific citations to particular parts of materials in the record that the responding party asserts demonstrate a dispute . . reproduc[ing] each numbered paragraph of the moving party's statement before including the response thereto." V.R.C.P. 56(c)(2). Should a party fail to submit the response required under this sub-part, the rule gives the court the option of "consider[ing] the fact[s] undisputed for the purposes of this motion." V.R.C.P. 56(e)(2).

Ms. Kurt submitted a "Motion to Dismiss" that appears to respond to some of Plaintiffs' claims. The court deems this submission to be an opposition to Plaintiffs' motion for summary judgment but finds Ms. Kurt's filing does not meet the requirements of V.R.C.P. 56(e)(2). Specifically, Ms. Kurt failed to respond to Plaintiffs' Statement of Undisputed Material Facts or point the court to any evidence disputing any of the statements. Thus, the court will treat the facts submitted by Plaintiffs as undisputed for the purposes of this motion. Defendant's Opposition, filed 10/14/2024.

Undisputed Facts

In 1999, VLT conveyed a parcel of property to itself, VHCB, and VAAFM for the purpose of placing a conservation easement on approximately 186 acres of land formerly known as the "Cota Farm J Parcel." Plaintiffs' Statement of Undisputed Material Facts (""SUMF"), 2. The deed for the land notes that the primary purpose of the restriction is to "conserve productive agricultural and forestry lands in order to facilitate active and economically viable farm use of the Protected Property now and in the future." Plaintiffs' Statement of Undisputed Material Facts, Exhibit 1, filed 9/5/24, at 1; SUMF q 8. The restrictions required to achieve this purpose run with the land. SUMF Ex. 1 at 1, SUMF 1 6.

Entry Regarding Motion Page 1 of 7 23-CV-02766 Vermont Land Trust et al v. Kerry Kurt et al As part of achieving this purpose, the easement forbids “residential, commercial, industrial, or mining activities . . . except as specifically permitted under this grant.” SUMF Ex. 1 at 2, SUMF ¶ 10. Additionally, the easement states that “no building, structure, or appurtenant facility or improvement shall be constructed, created, installed, erected, or moved onto the Protected Property” except as permitted by Plaintiffs. Id. “Permitted uses” include the right to construct, repair, or maintain “non-residential structures” like barns and sugar houses, as long as the buildings are used “exclusively for agricultural and forestry purposes” and have been approved in writing by Plaintiffs. SUMF Ex. 1 at 3, SUMF ¶ 11. The restrictions allow for repair and replacement of buildings within the designated “old farmstead complex,” which includes one residential building. Although the deed includes references to a planned new residence, it also details procedures for vacating the old residence and clearly indicates that “Only one residence shall be occupied on the protected property . . . .” SUMF Ex. 1 at 4, SUMF ¶¶ 13.

To enforce these restrictions, the deed lays out a multi-step process designed to encourage voluntary compliance. Plaintiffs have the right to make regular inspections of any part of the property, and they have a “right of reasonable access” in order to do so. Ex. 1 at 4, SUMF ¶ 17. If Plaintiffs become aware of a violation of the terms of the easement, they must give notice to the property owner and demand corrective action. Id. Should this notice fail to encourage the owner to bring the property into compliance with the deed’s restrictions, its terms “entitle [Plaintiffs] to bring an action in a court of competent jurisdiction to enforce the terms of this Grant . . . .” Ex. 1 at 5, SUMF ¶ 17.

In 2005, the prior owners of the Cota Farm Parcel (burdened by the 1999 conservation easement) conveyed their property to Ms. Kurt and another individual. SUMF Exhibit 3, submitted 9/5/2024, at 1. That other individual quitclaimed their interest in the land to Ms. Kurt in 2015, making her the sole owner of the property. Id; SUMF ¶ 18. In 2017, Ms. Kurt purchased an additional 13 acres of land from the town of Starksboro, which she added to the land burdened by the conservation easement through an amendment to the original deed. SUMF Exhibit 5, submitted 9/5/24, at 1; SUMF ¶¶ 19-20. Prior to the amendment, Ms. Kurt signed a document, called a “Baseline Documentation Report,” that attested to the condition of both pieces of property and described the planned land transaction. SUMF Exhibit 6, submitted 9/5/2024. This document affirmed that there were no structures on the land being added to the easement, nor were any activities occurring on her property that were inconsistent with the original deed. SUMF Ex. 6, p. 3, 5, SUMF ¶ 21. Further, she signed the amendment to the original deed, which states that “In all other respects, the Original Grant is unchanged and remains in full force and effect.” SUMF Ex. 5, p. 1.

In January 2023, a community member alerted VLT to the possibility of an unauthorized structure being used as a residence on the property. SUMF Exhibit 9, submitted 9/5/2024, at 1. Investigation by Plaintiffs revealed videos of a number of structures that did not comply with the terms of the easement, posted by Mr. Kurt to a YouTube channel. SUMF ¶ 25-26. In March of that year, VLT attempted to notify Ms. Kurt of noncompliance with the terms of the conservation restrictions, as required by the deed. SUMF ¶ 28; SUMF Ex. 1, p. 4. After receiving no response, VLT delivered notice to Ms. Kurt in person on May 6th, 2023. SUMF ¶ 29. On May 7th and 8th, counsel for VLT exchanged emails with Mr. Kurt in which he acknowledged he built the unauthorized structures and asserted that VLT had no rights in the 13-acre lot added to the original deed in 2017. SUMF Exhibit 12, submitted 9/5/2024, at 3; SUMF ¶ 30. Mr. Kurt also acknowledged that he was living on the property; during this exchange, he asserted that when Ms. Kurt purchased the land in 2017, he had “settled said land, [and] lived there permanently for many years . . . .” Id.; SUMF ¶31.

Summary Judgment Standards

A party is entitled to summary judgment if “there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” V.R.C.P. 56(a). A fact is material “‘if it might

Entry Regarding Motion Page 2 of 7 23-CV-02766 Vermont Land Trust et al v. Kerry Kurt et al affect the outcome.’” In re Estate of Fitzsimmons, 2013 VT 95, ¶ 13, 195 Vt. 94 (quoting N. Sec. Ins. Co. v. Rossitto, 171 Vt.

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Vt Land Trust v. Kurt, Counsel Stack Legal Research, https://law.counselstack.com/opinion/vt-land-trust-v-kurt-vtsuperct-2024.