Wallace Farm, LLC v. Mark Sacco

CourtSupreme Court of New Hampshire
DecidedJuly 13, 2021
Docket2020-0556
StatusUnpublished

This text of Wallace Farm, LLC v. Mark Sacco (Wallace Farm, LLC v. Mark Sacco) is published on Counsel Stack Legal Research, covering Supreme Court of New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Wallace Farm, LLC v. Mark Sacco, (N.H. 2021).

Opinion

THE STATE OF NEW HAMPSHIRE

SUPREME COURT

In Case No. 2020-0556, Wallace Farm, LLC v. Mark Sacco, the court on July 13, 2021, issued the following order:

Having considered the briefs and record submitted on appeal, we conclude that oral argument is unnecessary in this case. See Sup. Ct. R. 18(1). The defendant, Mark Sacco (tenant), appeals a decision of the Circuit Court (Steckowych, J.) granting possession to the plaintiff, Wallace Farm, LLC (landlord), of residential property for good cause based upon the tenant’s failure, following written notice, to remove a satellite dish installed in violation of the parties’ lease. See RSA 540:2, II(e), III (Supp. 2020). On appeal, the tenant argues that the trial court erred by not dismissing the case based upon the federal “Over-the-Air Reception Devices” (OTARD) rule, see 47 C.F.R. § 1.4000(a) (2019). We affirm.

The OTARD rule provides, in relevant part:

Any restriction, including but not limited to . . . any private covenant, contract provision, [or] lease provision, . . . on property within the exclusive use or control of the antenna user where the user has a direct or indirect ownership or leasehold interest in the property that impairs the installation, maintenance, or use of: (i) An antenna that is: (A) Used to receive direct broadcast satellite service, including direct-to-home satellite service, or to receive or transmit fixed wireless signals via satellite, and (B) One meter or less in diameter . . . . . . is prohibited to the extent it so impairs . . . .

47 C.F.R. § 1.4000(a)(1).

Evidence in the record, including photographs introduced at trial, establishes that the tenant leases a residential apartment in a large, multi-unit apartment building containing apartments on three stories with balconies on the upper-story units and patios on the first-story units. The landscaping on the side of the building where the tenant’s first floor apartment is located includes a large grass lawn with some shrubbery immediately adjacent to the building. Several feet from the side of the tenant’s apartment, on the grass lawn, is a satellite television dish affixed to a pole that is several feet in height and secured to the ground. Cable runs from the satellite dish and enters the apartment building through holes drilled into its exterior wall. The lease defines the premises as “[a] 2 bedroom apartment located at: 9 BRIDLE PATH #104 Londonderry, NH 03053.” It obligates the landlord to “maintain the apartment building, the common grounds, the apartment and [its] equipment . . . in good condition in compliance with . . . all applicable laws, rules and regulations of the State, its agencies and any applicable municipal codes.” It obligates the tenant not to “embellish and/or change, nor make any additions or alterations to the apartment,” or to “install . . . antennas or other like . . . equipment” without the landlord’s written permission. It also requires the tenant to keep “[s]idewalks, passages, public halls, stairwells, fire escapes, etc.” free from obstructions, and prohibits their use “for any purpose other than ingress and egress to the premises.” The lease prohibits the tenant from using “[b]alconies and patios . . . as storage areas,” and requires the tenant to keep “[c]ommon areas including stairwells, landings, balconies and grounds . . . free of any personal belongings.” The lease specifically provides that “[s]atellite [d]ishes are NOT permitted.”

On April 29, 2020, the landlord provided written notice to the tenant advising that on the previous day, the landlord had observed a satellite dish installed “on the ground outside [of his] apartment,” that the satellite dish violated the lease, and that he was required to remove and dispose of it and repair all exterior or interior drilled holes no later than May 8, 2020. If the tenant failed to comply, the landlord warned that it would commence an eviction. The tenant did not comply with the notice.

On May 8, 2020, the landlord wrote a second letter to the tenant demanding that he “immediately” remove the satellite dish, and warning that if he failed to do so, it would commence legal proceedings. The tenant failed to respond to the May 8 letter, or otherwise to comply with its demand.

On June 23, 2020, the landlord wrote a third letter to the tenant advising that he had failed to remove the satellite dish and restore the building to its original condition, that maintaining the satellite dish violates the lease, and that if he failed to remove the satellite dish and restore the building immediately, the landlord would commence legal proceedings. The tenant again failed to respond, and on August 5, 2020, the landlord served an eviction notice requiring that he vacate the property by September 10.

At the hearing on the eviction, the tenant did not contest that he had installed the satellite dish, or that doing so violated the lease. Instead, for the first time, he took the position that the OTARD rule “allows a tenant to place satellite dishes of certain sizes on apartments,” and that the OTARD rule supersedes the inconsistent lease provision. He further claimed that he had “received oral permission from [the landlord] . . . to install the dish on the ground next to his apartment.” In awarding possession to the landlord, the trial court found that the tenant materially breached the lease, and that he failed to cure the breach despite being provided notice and an opportunity to cure it. The trial court further found the tenant’s claim that he received oral 2 permission to install the satellite dish not to be credible. The trial court did not expressly address the tenant’s argument under the OTARD rule.

On appeal, the tenant argues that the satellite dish met the criteria for protection under the OTARD rule. Accordingly, he contends that the trial court erred by not dismissing the case. The landlord counters that, because the tenant did not prove that he had exclusive use or control over the lawn adjacent to the apartment building, or to the building’s exterior wall, he was not protected by the OTARD rule. We agree with the landlord.

By its express language, the OTARD rule prohibits a lease restriction only “to the extent it . . . impairs” the “installation, maintenance, or use of” a qualifying satellite dish “on property within the exclusive use or control of the” tenant. 47 C.F.R. § 1.4000(a)(1) (emphasis added). The rule does not apply to the extent that the restriction impairs the installation, maintenance, or use of a satellite dish on property that is not within the tenant’s exclusive use or control, such as on property within the “common area” of leased property. See Building Owners and Managers Ass’n Int. v. F.C.C., 254 F.3d 89, 93 & n.4 (D.C. Cir. 2001) (observing that OTARD rule allows tenants to install certain satellite dishes wherever the tenants rent space outside a building, but not “on common property such as outside walls” or “restricted access areas such as rooftops”); Watson v. Village at Northshore I Ass’n, 184 A.3d 1133, 1152-53 (Vt. 2018) (ruling that condominium association was allowed to enforce ban on satellite dishes because the property to which a condominium unit owner sought to install a satellite dish constituted “common area” to which the owner did not have exclusive use and control); see also Burelle v. Pienkofski, 84 N.H.

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Wallace Farm, LLC v. Mark Sacco, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wallace-farm-llc-v-mark-sacco-nh-2021.