December 2022
Cao et al. v. PFP Dorsey et al. (Arizona Supreme Court)
In 2018, the Arizona Legislature amended A.R.S. §33-1228 to modify the procedure for terminating condominiums. In spring 2019, PFP Dorsey Investments, owner of more than 90% of the units (90 of 96 units) in Dorsey Place Condominiums in Tempe, Arizona, followed the procedures outlined in A.R.S. §33-1228 and the Declaration for Condominium for Dorsey Place and terminated the condominium. At the time, A.R.S. §33-1228 required agreement from 80% of the owners; the Declaration required 90%.
Jie Cao and Haining Xia, owners of a unit within Dorsey Place objected to termination (PFP Dorsey reached agreements with the other five-unit owners and each signed deeds transferring title in their respective units to PFP Dorsey). Instead of availing themselves of the arbitration process in the 2018 version of A.R.S. §33-1228, Cao and Xia sued PFP Dorsey and Dorsey Place Condominiums, claiming, among other things, that A.R.S. §33-1228 is an unconstitutional taking of their unit.
Dorsey Place Condominiums successfully moved to dismiss Cao and Xia complaint on the ground that they had properly terminated the condominium per the requirements of the 2018 version of A.R.S. §33-1228. Cao and Xia appealed on several grounds, not the least of which is their argument it is unconstitutional. In the interim (and after oral argument), the Arizona Supreme Court (“ASC") issued its decision in Kalway v. Calabria Ranch HOA, LLC, 252 Ariz. 532 (2022). The Court of Appeals (“COA") requested both additional briefing just before the Supreme Court issued its Kalway decision and then supplemental briefing to address that decision.
Ultimately, the COA determined that A.R.S. §33-1228 was unconstitutional, except as to Cao and Xia because they had accepted the Declaration when they purchased their unit and the Declaration expressly incorporated the Arizona Condominium Act (A.R.S. §33-1201 et seq.) However, the COA also found that in light of Kalway, any amendments to statutes also acted as amendments to the Declaration and unless those amendments were reasonably foreseeable by Cao and Xia, the amendments did not apply to Cao and Xia, and they are governed by the version of the statute in effect at the time they purchased their unit.
The Arizona Court of Appeals in Cao/Jie v. PFP Dorsey et al. has decided that if there are “substantive post-purchase" amendments to A.R.S. §33-1228 (the Arizona condominium termination statute), the version of the statute in place at the time an owner purchased their unit, controls the owner's interests and rights vis-à-vis termination. “Substantive post-purchase" amendments is not further clarified. We believe if this decision is allowed to stand, it will apply to more than just the condominium termination statute.
Further, it will result in associations being forced to treat owners differently depending upon which version of a statute is in effect at purchase and even whether an owner may choose to “opt in" to a particular version of a statute. This decision has the potential to require an association to treat its members differently, and potentially inequitably, in contravention of Tierra Ranchos Homeowners Association v. Kitchukov 216 Ariz. 195 (App. 2007) and RESTATEMENT (THIRD) OF PROPERTY (SERVITUDES) §6.13.
Amicus Brief
Supplemental Amicus Brief
Washington State Supreme Court Opinion March 2024
Court: Arizona Supreme Court
Topic: Condominium Termination
Brief Author: Lynn Krupnik, Esq., CCAL, Krupnik & Speas, PLLC, Tim Krupnik, Esq., Krupnik & Speas, PLLC, and Quinton Cupps, Vial Fotheringham, LLP, Robert Diamond, Reed Smith, LLP, and James C. Martin and Ted A. Hages, Reed Smith, LLP
Filed: December 19, 2022
CAI Amicus Review Panel: Mr. Robert Diamond, Esq., CCAL, Co-Chair of Amicus Committee
Mr. Stephen Marcus, Esq., CCAL, Co-Chair of Amicus Committee
Mr. Henry Goodman, Esq., CCAL (MA)
Ms. Karyn Kennedy Branco, Esq., CCAL (NJ)
Ms. Melissa Francis, Esq. (MI)
Mr. Daniel Heaton, Esq. (CA)
Elizabeth Trace Condominium Association vs. American Global Enterprises
Plaintiff/appellee, Elizabeth Trace Condominium Association (the “Association"), is responsible for administering and operating a 46-unit condominium project in White Lake Township, Michigan that was established on May 25, 2004. When the condominium project was created, only units 42 through 46 were labeled as “must be built" in the Condominium Documents, with units 1 through 41 being labeled as “need not be built." The Condominium's first developer-built units 1 through 14 and 42 through 46, but units 15 to 41 (the “Unbuilt Units") were never built and to this day have never been built.
On December 18, 2009, the Unbuilt Units were conveyed from the Condominium's first developer to its mortgagor via a deed in lieu of foreclosure, and on October 2, 2012, the mortgagor conveyed the Unbuilt Units to defendant/appellant, American Global Enterprises, Inc. (“AEG").
In 2016, MCL 559.167 was amended to read as it currently does today, stating, in pertinent part, the following:
(3) Notwithstanding section 33, for 10 years after the recording of the master deed, the developer . . . may withdraw from the project any undeveloped land or convert the undeveloped condominium units located thereon to “must be built" without the prior consent of any co-owners . . .
On December 14, 2018, the Association filed a lawsuit against AEG, claiming that ownership of the Unbuilt Units had reverted to general common elements by operation of law under the prior version of MCL 559.167 because the Unbuilt Units had not been developed, constructed, or withdrawn from the Condominium by the end of 2014. The Michigan trial court agreed, holding that the Unbuilt Units had ceased to exist and that those Unbuilt Units had become general common elements within the Condominium.
AEG appealed the trial court's decision to the Michigan Court of Appeals, arguing that the Unbuilt Units had not reverted to general common elements by operation of law and, therefore, could still be constructed on the following grounds: (1) it was not a developer under the Michigan Condominium Act and, therefore, MCL 559.167(3) did not apply to it, (2) the application of the prior version of MCL 559.167(3) in this case would render an absurd result in which a non-developer could lose its land because of a prior developer's failure to take certain action, (3) construction of the surrounding common elements had taken place, and, therefore, MCL 559.167(3) did not apply, and (4) the application of the prior version of MCL 559.167(3) in this case would result in an unconstitutional taking without due process of law under the Fifth Amendment to the United States Constitution.
In a published opinion, the Michigan Court of Appeals rejected all of AEG's arguments and upheld the trial court's decision, primarily because of another published opinion out of the Michigan Court of Appeals, Cove Creek Condominium Association v Vistal Land & Home Development, LLC, 330 Mich App 679 (2019), which held that the 2016 version of MCL 559.167(3) did not apply retroactively and a condominium developer could lose all their rights to construct unbuilt units as a result of the expiration of the statutory time period in the prior version of MCL 559.167(3). Cove Creek also expressly rejected the argument that the loss of property rights by operation of law under the prior version of MCL 559.167(3) resulted in an unconstitutional taking without due process of law, consistent with other Michigan Supreme Court precedents holding that the Michigan legislature could condition the retention of property rights on the performance of certain actions indicating an intention to retain that property interest.
Amicus Brief
Michigan Supreme Court Order Denying Application Leave to Appeal - March 2023
Court: Supreme Court of Michigan
Topic: Developer Control
Brief Author: Kevin M. Hirzel, Esq., CCAL, and Kayleigh B. Long, Esq., Hirzel Law, LLC
Filed: December 2, 2022
CAI Amicus Review Panel: Mr. Robert Diamond, Esq., CCAL, Co-Chair of Amicus Committee
Mr. Stephen Marcus, Esq., CCAL, Co-Chair of Amicus Committee
Mr. Thomas Moriarty, Esq., CCAL (MA)
Ms. Mary Howell, Esq., CCAL (CA)
Ms. Lydia Linsmeier, Esq. (AZ)
October 2022
Avatar Properties, Inc. v. Gundel, Case No. 2D21-3823 (Second District Court of Appeal, State of Florida)
The brief is in support of residents of a community in litigation they brought successfully challenging the developer's attempt to use community assessments to secure a perpetual, lien-enforceable profit. The assessment at issue was not only in excess of community expenses, it was imposed through means intended to deprive residents of any association, vote, or input over its amount or duration. The residents won a judgment in the trial court holding the additional assessment, called a Club Membership Fee, was in violation of the Florida Homeowners' Association Act and requiring the developer to pay back the fees collected since April 2013.
The developer has appealed the judgment, and it has enlisted a proposed amicus brief from the Florida Home Builders Association. Both the developer's brief and the FHBA's amicus brief argue that imposing assessments for profit on developer-owned property without any community input is lawful. And the FHBA has relied heavily on CAI statistics to suggest that prohibiting developers from doing this would have a widespread and negative impact on builders—even though it acknowledged that it has no statistics at all on the number of builders attempting to impose this particular scheme.
The Developer has raised two issues on appeal. In the first issue, the Developer contends that the Club Membership Fee assessment is permitted under chapter 720 or generally by law. In the second issue, the Developer contends the residents are estopped from challenging the legality of the Club Membership Fee either because they “voluntarily" paid it, or because of the provision in the Club Plan that prohibits a resident from challenging the validity of the plan. The residents' answer brief will explain: (1) The Club Membership Fee violates section 720.308, Florida Statutes because it is an assessment in excess of a resident's proportionate share of expenses; (2) the whole text of chapter 720 confirms the Club Membership Fee is unlawful; (3) the residents' payment of the assessments was not voluntary and so does not estop them from challenging the legality of those payments; and (4) the provision in the Club Plan purporting to prohibit residents from challenging the legality of the plan is unenforceable.
This appeal presents critical issues regarding (1) a community's self-governance and (2) a developer's ability to try to immunize itself for violations of the homeowners' act. If the appellate court were to issue an opinion that permits the Developer's scheme to stand, developers will have every incentive to copy it in every development because it provides a developer a perpetual and guaranteed profit. Developers would then be free to keep title and control over important aspects of every community development; impose lien-enforceable assessments to pay all of the costs and operating expenses for the developer's assets and to also provide the developer a guaranteed, perpetual profit stream; and yet deprive homeowners of any association or vote over the amount or use of the assessments or the assets. The residents' rights to self-governance regarding their community and the assessments they are required to pay for it would be severely limited.
Amicus Brief
Sixth District Court of Appeal, State of Florida, Opinion
Supreme Court declined jurisdiction
Court: Second District Court of Appeal, State of Florida
Topic: Developer imposed assessments
Brief Author: Lisa Magill, and Shawn Brown of Kaye Bender Rembaum, Florida
Filed: October 5, 2022
CAI Amicus Review Panel: Mr. Robert Diamond, Esq., Mr. Stephen Marcus, Esq., Ms. Gabriella Comstock, Esq., CCAL (IL), Mr. J. David Ramsey, Esq., CCAL (NJ), Mr. Tiago Bezerra, Esq. (VA), Ms. Joan Lewis-Heard, Esq. (CA), Mr. William Ward, Esq. (CT)
June 2022
7205 Telegraph, LLC v. Telegraph Square II, a Condominium Unit Owners Association (Virginia Court of Appeals)
This case involves a dispute over parking in a wholly commercial condominium and the proper allocation of assessments. Defendant and Appellant is Telegraph Square II, a Condominium Unit Owners Association, Inc. Plaintiff is the owner of three units in the condominium, 7205 Telegraph Square, LLC. William Akers owns 7205 Telegraph Square LLC. With a complex set of facts in this matter, we find it important to explain the importance of the impact of this case at the onset of this memorandum. Because of the breadth of the judge's opinion, there are both Virginia and national issues raised by this case. The judge's opinion in this matter ignored and rewrote condominium documents and then refused to apply the business judgment rule. The ability of a condominium to designate a Reserved Common Element (essentially a license) when the Condominium Act expressly allows the executive board of an association to grant an easement (a greater right than a license) is a national issue because the Uniform Condominium Act and Uniform Common Interest Ownership Act both empower a condominium association to do so and many condominium documents provide the executive board with that power. Finally, in almost all jurisdictions the law requires a unit owner to pay any disputed assessment and then to challenge the validity of the assessment. Judge Bellows' opinion reversed that rule and allowed the Plaintiff to refuse to pay assessments for four years while it disputed the amount of the assessment. That result would severely impact many associations which could not pay their essential expenses and would require the other unit owners to pay additional assessments to cover expenses while the disputing owner refused to pay.
The amicus requestor and review panel would like to utilize this amicus brief to clarify several issues, negatively impacting condominium law in Virginia, presented by the judge's opinion including, but not limited to,
(1) the proper use and assignment of reserve common elements versus limited common elements of a condominium association;
(2) that it is not permissible to withhold payment of condominium assessments while disputing the amount or validity of an assessment (rather, similar to the procedure for contesting real estate taxes, condominium owners must first pay the assessments and then contest the amount due;
(3) courts have no authority to amend (rather than interpret) the condominium documents absent the procedure set forth in the condominium act where a judge can reform the documents at the request of the unit owners association;
(4) The business judgment rule applies to Board action when the actions are based on the advice of counsel and are consistent with the law and the documents.
The fact pattern in this case is as follows:
The Condominium now has five phases, but when it was originally developed in 1990, it only had one phase (“Phase I"). Several developers experienced financial difficulties and the other phases were developed by different entities over the next few years. As a condition of not opposing the development of additional phases, the unit owners in Phase I insisted on two conditions: (1) that all future phases be self-contained and required to maintain their own phases and (2) that the future phases continue to contribute to the cost of maintaining Phase 1. Although this might seem unfair, that was the bargained-for amendment to the condominium documents.
The Condominium's Board of Directors agreed that the arrangement under the Condominium documents was unfair, and it decided to change the method of allocating expenses. In 1997, the Board, although it did not have the legal authority to do so, re-allocated the maintenance costs in a more equitable manner so that the association maintained the asphalt in all phases as a common expense. The Board did not amend the condominium documents when it made these changes.
In 2015, however, the Board engaged an attorney who advised them that they were in violation of the condominium documents and recommended three things: (1) that the condominium documents be amended to conform to a fair allocation of maintenance responsibilities and assessments, (2) that in the meantime the assessments be allocated as required by the condominium documents and (3) that the common element parking spaces in Phase I be allocated as Reserved Common Elements to the units in Phase I since each other phase had the exclusive right to park in its own phase. On October 8, 2015, the Board passed a resolution assigning the parking spaces in Phase I for the exclusive use of the unit owners in Phase I. Although the resolution did not use the term, the Board acted pursuant to an express power to assign “Reserved Common Elements" given to the Board in both the Declaration and Bylaws. The reasoning was that all other phases had the exclusive use of limited common element parking spaces within the phase so that it was fair that unit owners in Phase I had similar rights—but as Reserved Common Elements not as limited common elements, as permitted by the condominium documents. For the next several years, including a period when Akers was President of the unit owners association, the budget was based on the condominium documents and several attorneys were engaged to revise the condominium documents. Unfortunately, the requisite unanimous vote of the unit owners was not obtained.
On August 29, 2019, Plaintiff filed suit against the Condominium. Plaintiff made three assertions to justify its request for an injunction and damages. First, Plaintiff argued that the assignment of parking spaces in Phase I as Reserved Common Elements to the units in Phase I was improper because (1) it “impermissibly diminished 7205 Telegraph's undivided interest in the common elements of the Condominium"; (2) it was discriminatory because any such assignment of parking spaces must be allocated equally to all units; and (3) it caused its phase to violate the parking requirements of the Fairfax County zoning ordinance. Second, Plaintiff argued that it was improperly assessed for common expenses related to Phase I. Third, Plaintiff argued that it was improperly assessed for legal expenses arising out of the parties' dispute.
In separate litigation, the Association sued 7205 Telegraph, LLC for almost $100,000 in assessments which had not been paid in over four years. The Association also filed liens against the delinquent's units.
On January 14, 2022, Judge Randy I. Bellows issued a Final Order attaching a transcript of his opinion read from the bench; there is no formal written opinion in the case. Judge Bellows held for Akers on all claims and awarded (1) damages of $481,434.84; (2) reduced Akers' outstanding assessments by $51,074.18 and credited him $6,296.70 in over-assessments; and (3) awarded attorneys' fees and costs of $324,977.60. See Exhibit A. The Judge also held that the parking scheme violated the Condominium Instruments and Fairfax County zoning ordinance and ordered that parking restrictions on the common element parking in Phase I be lifted. Id. The judge's detailed findings are outlined in the transcript of his ruling.
Amicus Brief
Court: Virginia Court of Appeals
Topic: Declaration amendments
Brief Author: Chadwick, Washington, Moriarty, Elmore & Bunn, P.C.
Filed: June 3, 2022
CAI Amicus Review Panel: Stephen Marcus, Esq., CCAL, Co-Chair of Amicus Committee, Steven Sugarman, Esq., CCAL (PA), Anthony Rafel, Esq., CCAL (WA), Edmund Allcock, Esq., CCAL (MA), Russell Robbins, Esq. (FL), and Elia Ellis, Esq. (MO)
May 2022
Richard Mountz, et al., vs. Mountain Gate Property Owners Association, Inc. (Arizona Court of Appeals)
Appellant Mountain Gate Property Owners Association, Inc. ("Association") recorded an amendment to the declaration in 2020 which, in part, prohibited rentals of less than thirty days ("Amendment"). The Amendment was adopted in conformance with the procedures set forth in the Arizona Planned Community Act (A.R.S. §33-1817): (1) that it be approved by the vote or written consent of the number of owners specified in the declaration; and (2) that it be prepared, executed, and recorded by the association within thirty days after its adoption.
Approximately three months after the Amendment was recorded, four owners (Appellants) filed an action against the Association challenging the validity of the Amendment on several grounds. After a hearing on the matter, the trial judge found in favor of the Appellants and declared the Amendment to be invalid on two of the grounds: (1) that the Amendment was not signed by owners as required by the declaration; (2) that a short-term rental restriction was not foreseeable and thus, the declaration's generic amendment provision was insufficient to create requirements that changed the obligations of owners.
The Association filed an appeal of the trial judge's decision, and its opening brief was filed on January 14, 2022. The original action was filed in the Superior Court for Navajo County, Arizona. The appeal is pending in the Arizona Court of Appeals.
Amicus Brief
Arizona Court of Appeals Opinion - November 2022
Court: Arizona Court of Appeals
Topic: Declaration amendments
Brief Author: Scott Carpenter, Esq., CCAL, Carpenter Hazelwood, LLC
Filed: May 4, 2022
CAI Amicus Review Panel: Mr. Robert Diamond, Esq., CCAL, Co-Chair of Amicus Committee, Mr. Stephen Marcus, Esq., CCAL, Co-Chair of Amicus Committee, Mr. Thomas Moriarty, Esq., CCAL (MA), Ms. Mary Howell, Esq., CCAL (CA)
April 2022
Executive Office Park of Durham Association, Inc. v. Rock (North Carolina Supreme Court)
The Association's case against the Respondent-Appellee Martin E. Rock a/k/a Martin A. Rock (Rock) concerns whether the Association, an office park condominium in Durham, North Carolina, formed before October 1, 1986, may foreclose a lien for assessments by power of sale pursuant to the provisions of the North Carolina Condominium Act. The Association filed its power of sale foreclosure in 2018 to enforce a Claim of Lien of event date filed pursuant to N.C. Gen. Stat. § 47C-3-116.1 The Association prevailed at the trial court. At the trial court, the trial court (both the Durham County Clerk of Court and the Durham County Superior Court, on appeal) agreed with the Association that the Association could use the provisions of the North Carolina Condominium Act (N.C. Gen. Stat. § 47C-1-101, et. seq. (the Act)), and, specifically, N.C. Gen. Stat. § 47C-3-116 to foreclose the Claim of Lien by power of sale. The North Carolina Court of Appeals reversed and remanded the case to the trial court for dismissal with a unanimous, published opinion concluding that the Act did not apply to the Association. The Court of Appeals' opinion completely ignored the fact that portions of the Act, including N.C. Gen. Stat. § 47C-3-116, are expressly applicable to condominium associations like the Association, formed on or before October 1, 1986. The Court of Appeals' opinion did not even address, in its entirety, N.C. Gen. Stat.§ 47C-1-102, which expressly makes certain provisions of the Act applicable to condominiums created on or before October 1, 1986. The Association petitioned the Supreme Court on this issue, and the Supreme Court allowed its Petition for Discretionary Review on February 9, 2022.
The Association respectfully requests that CAI permit the North Carolina Chapter of CAI to move the Supreme Court for leave to file an Amicus Curiae brief in support of the
Association's appeal. The Association's appeal is critical to the future assessment collection matters for pre-October 1, 1986, condominium associations. Should the Court of Appeals' opinion stand, such foreclosures would all have to be pursued as judicial foreclosures, significantly increasing the costs for the same to the association(s), and ultimately to the Unit Owners. However, the implications of the Court of Appeals' published opinion do not end with condominium collections. It is not a stretch to extrapolate the Court of Appeals' opinion to conclude that no provisions of the Act are applicable to pre-October 1, 1986, condominiums, and nor are any provisions of the North Carolina Planned Community Act (N.C. Gen. Stat.§ 47F-1-101, et. seq.)2 applicable to planned communities formed before January 1, 1999. Should that be the case, operation of condominiums and planned communities, depending on when formed, will be significantly impaired in North Carolina. The CAI Amicus Review panel have approved a CAI national amicus brief in this matter, upon review, due to the applicability of the Uniform Acts to pre-existing communities being critical and will become even more important given the recent change to the applicability section of the Uniform Acts.
Amicus Brief
Supreme Court of North Carolina Opinion - November 2022
Court: North Carolina Supreme Court
Topic: North Carolina Uniform Condo Act
Brief Author: Cynthia A. Jones, Esq. of Sellers Ayers Dortch Lyons, Charlotte, North Carolina
Filed: April 18, 2022
CAI Amicus Review Panel: Mr. Robert Diamond, Esq., CCAL, Co-Chair of Amicus Committee, Mr. Stephen Marcus, Esq., CCAL, Co-Chair of Amicus Committee, Mr. Henry Goodman, Esq., CCAL (MA), Ms. Karyn A. Kennedy Branco, Esq., CCAL (NJ), Ms. Melissa Francis, Esq. (MI), Ms. Daniel Heaton, Esq. (CA)
C Investments 2, LLC v. Arlene Auger, et al.
(North Carolina Supreme Court)
This lawsuit was filed in 2018 by C Investments 2 LLC, a real estate developer in Charlotte North Carolina. The Plaintiff sued all the lot owners in a neighborhood called Country Colony in Mecklenburg County, North Carolina. Country Colony was established in 1952, and consisted at that time of 17 residential lots. A copy of the plat map for Country Colony is attached to this Executive Summary as Exhibit A. The developers of Country Colony, Henry Newson and Miriam Newson, recorded Protective Covenants for Country Colony, and all lots were sold subject to the Protective Covenants. A copy of the Protective Covenants is attached to this Executive Summary as Exhibit B. Country Colony continues to be a single-family residential neighborhood developed in accordance with scheme of development set forth by the Newsons in the Protective Covenants. However, Plaintiff acquired several of the lots in Country Colony and seeks to subdivide them and to construct substantial multifamily projects on the lots it owns.
The main issue advanced by the Plaintiff, and the primary issue on appeal, is whether or not the North Carolina Marketable Title Act, N.C.G.S. § 478-1, et seq., has extinguished a// the Protective Covenants other than the residential use restriction . Specifically, the Plaintiff successfully argued to the trial court and the Court of Appeals that the Marketable Title Act extinguished all of the restrictions other than the residential use restriction, because none of the exceptions in the Act applied. We, representing a group of the Defendants, argued that the exception contained in N.C.G.S. § 478-3(13) protected all the scheme of development restrictions set forth in the Protective Covenants filed by the Newsons. There is one (1) issue on appeal:
1) Does the exception to the real property Marketable Title Act contained in N.C.G.S.§ 478-3(13), protect all of the restrictive covenants imposed for Country Colony under the Newsons' common scheme of development, or does it merely protect the residential use only restriction.
The Court's ruling, if upheld will adversely affect every neighborhood association in the State of North Carolina. The Court of Appeals decision would effectively allow developers to avoid the protective covenants for most planned communities in North Carolina, except for the residential use restriction. The elimination of single-family restrictions, setback restrictions, height restrictions, and the numerous other standard restrictions which form the scheme of development for most neighborhoods in North Carolina are at risk if this opinion is upheld by the Supreme Court. This will be a landmark decision affecting the practice a real estate in the State of North Carolina from Murphy to Manteo. It is extremely important that the decision be reversed, and the exception to the Marketable Title Act be interpreted to include all the restrictive covenants set forth in the scheme of development of each neighborhood. We believe strongly this was intent of the drafters of the legislation. This has been confirmed by conversations with the leading proponent of the legislation. The trial courts in North Carolina have differed on this issue, so it is ripe for determination to settle the law in the State of North Carolina.
Amicus Brief
Supreme Court of
North Carolina Opinion – December 2022
Court: North Carolina Supreme Court
Topic: North Carolina Marketable Title Act
Brief Author: H. Weldon Jones, III, of Jordan Price in Raleigh, North Carolina
Filed: April 12, 2022
CAI Amicus Review Panel: Mr. Robert Diamond, Esq., Mr. Stephen Marcus, Esq., Ms. Hope Carmichael, Esq (NC), Mr. Clint Goodman, Esq. (AZ), Ms. Terry A. Kessler Esq. (NJ), Ms. Melissa Ward, Esq. (CA), and Mr. Scott Weiss, Esq. (TN)
Check for a typo in the URL, or
go to the site home