WF Property Owners Association, Inc. v. Waterford Development Partners, L.P.

CourtTexas Court of Appeals, 3rd District (Austin)
DecidedJanuary 30, 2026
Docket03-24-00027-CV
StatusPublished

This text of WF Property Owners Association, Inc. v. Waterford Development Partners, L.P. (WF Property Owners Association, Inc. v. Waterford Development Partners, L.P.) is published on Counsel Stack Legal Research, covering Texas Court of Appeals, 3rd District (Austin) primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
WF Property Owners Association, Inc. v. Waterford Development Partners, L.P., (Tex. Ct. App. 2026).

Opinion

TEXAS COURT OF APPEALS, THIRD DISTRICT, AT AUSTIN

NO. 03-24-00027-CV

WF Property Owners Association, Inc., Appellant

v.

Waterford Development Partners, L.P., Appellee

FROM THE 53RD DISTRICT COURT OF TRAVIS COUNTY NO. D-1-GN-21-002370, THE HONORABLE MARIA CANTÚ HEXSEL, JUDGE PRESIDING

MEMORANDUM OPINION

This suit involves roads owned by a property-owners association within a tract of

land that abuts a marina. At issue is whether the tract south of the one with the roads and marina

benefits from an express easement burdening the roads.1 To benefit, the southern tract must come

within the words “the land and improvements commonly known as the ‘Waterford Marina.’”

WF Property Owners Association, Inc. appeals a summary-judgment ruling that

Waterford Development Partners, L.P. (Buyer) was entitled to a declaration that the easement at

issue, created in 2014, benefits the more southerly tract, which Buyer contracted to buy from

Waterford Lago Vista, LLC (Seller) in 2021. In one appellate issue, the Association contends that

the trial court erred by awarding Buyer that declaration and that the court should instead have

1 This appeal involves no claim for any implied easement or easement by necessity. This opinion should not be construed as addressing the availability, if any, of any implied easement or easement by necessity burdening the roads at issue. rendered a summary judgment in the Association’s favor that Buyer take nothing on its request for

the declaration.

Because no ordinary person in the relevant context of the creation of the easement

in 2014 would reasonably have understood the easement’s terms to have extended to benefit the

more southerly tract, we reverse the portion of the trial court’s judgment that awarded Buyer the

declaration at issue and render judgment that Buyer take nothing by its request for that declaration.

I

A

For the past 15 or so years, the shores of Lake Travis, in western Travis County,

have seen significant new residential development. One such area seeing development is called

“Waterford,” which lies on a peninsula. To Waterford’s north is the city of Lago Vista, and

to its south is the village of Point Venture. Tracts in Waterford were conveyed to Seller’s

predecessor-in-interest in 2013 by special-warranty deed (the 2013 Deed). Two of those tracts are

relevant here—one comprising roughly 36 acres and containing a marina since about 2008 (the

36-Acre Tract) and the other tract lying to the south of the 36-Acre Tract, comprising just under

52 acres, and lacking the level of development that the 36-Acre Tract has seen (the 52-Acre Tract).

While both tracts were being advertised for sale in 2013, a brochure circulated showing an aerial

photo of the tracts. In that photo, the 36-Acre Tract is called “Section 4A,” and the 52-Acre Tract

is called “Section 4B”:

2 The photo shows roads on the 36-Acre Tract and the marina abutting that tract. These roads are

private. Their only public-road access comes from a road called Lohman Ford Road.

In 2014, after a period of development on the 36-Acre Tract, Seller’s

predecessor-in-interest conveyed ownership of the tract’s roads to the Association, whose

members were to own homes built on the tract’s lots. Along with this conveyance of the roads,

the predecessor created and reserved an easement appurtenant burdening the roads for the benefit

of specified land (the 2014 Easement). The terms of the roads conveyance and of the 2014

Easement were set forth in contemporaneously executed documents—one a deed (the 2014 Deed)

and another an easement agreement (the 2014 Agreement). The 2014 Deed defined the land that

was to benefit from the easement over the Association’s roads.

3 After the 2014 Deed and the 2014 Agreement were executed, Seller’s

predecessor-in-interest conveyed the 52-Acre Tract to Seller. Then in 2021, Seller executed a

purchase-and-sale agreement to convey the 52-Acre Tract (the PSA). Because of assignments of

interest, Buyer acquired the rights under the PSA to buy the 52-Acre Tract from Seller. For

purposes of this appeal, we and the parties treat Buyer as enjoying all rights that the original buyer

party to the PSA enjoyed.

As part of Seller’s obligations under the PSA, Seller was to provide Buyer with a

means of accessing the 52-Acre Tract from Lohman Ford Road:

In order to access Lohman Ford Road from the [52-Acre Tract], [Buyer] requires access across certain roads and streets in the adjacent [36-Acre Tract]. Seller has agreed to provide [Buyer] with a mutually acceptable means of access across such roads and streets, and during the Inspection Period, Seller and [Buyer] shall use commercially reasonable efforts to agree upon the form of such access and to amend this Agreement to incorporate the terms of their agreement herein.

Buyer and Seller came to dispute exactly what this section of the PSA required and what its

inclusion meant for the PSA overall. One way in which the parties’ dispute manifested was during

assembly of the commitment of title insurance by the title company that was assisting with the

PSA’s transaction. During its work, the title company identified the 2014 Easement—which

burdens the Association’s roads—as the method by which Seller should carry out its obligation

under the PSA to provide Buyer with access from Lohman Ford Road to the 52-Acre Tract.

Seller’s representatives, however, questioned the title company about whether its interpretation of

the 2014 Easement was correct.

4 B

Buyer and Seller could not resolve their disputes over the PSA, so Buyer began this

suit. It later amended its pleadings to add a request for declaratory relief. In its live pleading,

Buyer requested a declaration that the 2014 Easement is an easement appurtenant that benefits the

52-Acre Tract. Because it was adding this request for relief, Buyer said that it also was adding

the Association as a defendant in the suit: “As the owner of the [burdened p]roperty, [the

Association]’s rights will be affected by the adjudication of this claim, and it has therefore been

added as an additional party Defendant.”

During the suit, the parties twice cross-moved for full or partial summary

judgments. The second time, Buyer and the Association cross-moved on Buyer’s request for the

declaration about the 2014 Easement. The trial court granted Buyer’s motion and denied the

Association’s. After a final trial on other matters, the court rendered its final judgment. The

summary-judgment ruling merged into the final judgment, and in the final judgment’s text, the

court awarded Buyer a declaration that the 2014 Easement “is a non-exclusive access easement

appurtenant that (i) benefits the owner (and successors and assigns, running with the land) of the

52-[A]cre [T]ract . . . and (ii) is for purposes of the dominant estate holder’s ingress and egress

across” the 36-Acre Tract’s roads. The final judgment also awarded, among other items, the

specific-performance relief that Seller was to close the transaction contemplated by the PSA.

The Association now appeals the portion of the judgment awarding the declaration

about the 2014 Easement, and, originally, Seller appealed the judgment as well.

II

The Association in its appellant’s brief raised two appellate issues, one of which

addresses the summary-judgment ruling about the declaration regarding the 2014 Easement and

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WF Property Owners Association, Inc. v. Waterford Development Partners, L.P., Counsel Stack Legal Research, https://law.counselstack.com/opinion/wf-property-owners-association-inc-v-waterford-development-partners-txctapp3-2026.