Justia Real Estate & Property Law Opinion Summaries

Several homeowners in subdivisions along the North Platte River disputed ownership of a strip of land, known as the “meander land,” that lies between a designated meander line (depicted in historical government surveys) and the current thread (centerline) of the river. Both sides had historically used this land as part of their backyards. The plaintiffs claimed title to this land under the meander line rule, arguing their property extended to the thread of the river, while the defendants asserted that deeds, subdivision plats, and a later quitclaim deed gave them title to the disputed area.The plaintiffs, who owned lots in the Red Butte Subdivision south of the river, initiated quiet title actions, which were consolidated in the District Court of Natrona County. The defendants owned adjacent property and a tract labeled “Park 10” in the Trails West Subdivision, which lies north of the river but was described as extending under the river to the meander line. The district court granted summary judgment for the plaintiffs, determining that the meander line rule applied and the plaintiffs’ property extended to the thread of the river, not just to the meander line.The Supreme Court of Wyoming reviewed the district court’s order de novo. It held that the meander line in the relevant deeds and plats was not the true boundary; rather, the property extended to the river’s thread, consistent with Wyoming law and the generally accepted meander line rule. The Court found no clear language in the deeds or plats fixing the boundary at the meander line. It further ruled that subdivision plats could not convey land not owned by the subdivider. Accordingly, the Supreme Court of Wyoming affirmed the district court’s grant of summary judgment, holding that the boundary between the parties’ properties is the thread of the North Platte River. View "Hein v. Carlson" on Justia Law

Two applicants submitted materials to operate medical cannabis cultivation facilities in a Maine town in August 2024. Their initial applications did not include necessary documentation showing that their facilities would be located in a “Registered Cannabis Property,” which was required by the town’s licensing ordinance. Town staff reviewed the applications and placed them on the council agenda for a “first reading,” a step not required by ordinance but adopted by custom. On September 4, 2024, before the first reading of the applications, the Town Council amended the zoning ordinance to add a 1,000-foot setback requirement between cannabis facilities and residential properties—a standard the applicants’ locations could not meet. After the amendment, staff told the council the applications were “complete,” and the first reading occurred. The public hearing and further review were scheduled, and the required property registration was later filed. The council ultimately denied the applications for failing to meet the new setback requirement.The applicants sought judicial review in the Cumberland County Superior Court under Maine Rule of Civil Procedure 80B. The Superior Court affirmed the Town Council’s decision, concluding that the applications were not “pending” at the time of the ordinance amendment and thus were subject to the new setback requirement.On further appeal, the Maine Supreme Judicial Court reviewed whether the applications were “pending” within the meaning of 1 M.R.S. § 302 at the time the ordinance was amended. The court held that an application is not “pending” until the reviewing authority has conducted a substantive review of whether it meets the approval criteria. Because the Town Council had not begun substantive review before the zoning amendment was enacted, the applications were not pending and were properly denied under the amended ordinance. The judgment was affirmed. View "Shark Tank Strategies, LLC v. Town of Scarborough" on Justia Law

Esplanade Properties Corporation, a subsidiary of R.H. Macy & Co., owned the Macy’s Parcel in Kenner, Louisiana. In 1992, while Esplanade Properties was under bankruptcy protection and subject to an automatic stay, Jefferson Parish assessed ad valorem taxes for that year. In 1993, the Sheriff conducted a tax sale for nonpayment of those taxes, but the sale was later nullified because it occurred during the bankruptcy stay. For nearly two decades, the Parish took no action to collect the 1992 taxes. After subsequent transfers, the property was acquired by Esplanade Mall Realty Holding, LLC, which in 2018 received notice of a large sum due for past taxes, including the 1992 taxes, interest, and costs. The company disputed the collectibility of the old taxes, citing a statutory three-year limitation on tax sales.The 24th Judicial District Court initially dismissed the suit on procedural grounds, and the Louisiana Fifth Circuit Court of Appeal affirmed. The Louisiana Supreme Court reversed and remanded. While proceedings continued, the property was sold to Pacifica Kenner, LLC, which was substituted as plaintiff. The trial court ultimately ruled that La. R.S. 47:2131—which prohibits tax sales for taxes more than three years overdue—was unconstitutional because it conflicted with Louisiana constitutional provisions regarding tax collection and prescription. The trial court denied declaratory relief to the plaintiff.The Supreme Court of Louisiana reviewed the case and chose to avoid the constitutional issue, finding it unnecessary to resolve the dispute. Interpreting the relevant statutes, the court concluded that the Sheriff was required to include all statutory impositions, including the 1992 taxes, interest, and costs, in the 2020 tax sale price. The court held that the redemption price for the property must likewise include these amounts. The judgment was reversed, rendered, and remanded to the trial court to calculate the redemption price consistent with this interpretation. View "ESPLANADE MALL REALTY HOLDINGS, LLC VS. LOPINTO" on Justia Law

A public port authority sought to acquire approximately twenty-nine acres of private, unimproved land owned by an individual in Plaquemines Parish, Louisiana. The expropriation was initiated as part of a larger project to develop a liquified natural gas (LNG) and container port complex. The authority intended to lease the acquired property to a private LNG company, Venture Global, for its exclusive development and use, including construction of LNG facilities and docks. The port authority asserted that the expropriation would serve public interests such as economic growth, job creation, energy security, and environmental stewardship, and advanced its mission of expanding port operations.After the port authority deposited the alleged just compensation in court, the landowner filed a motion to dismiss the expropriation, arguing that the taking lacked a public purpose under Louisiana law because its sole intent was to lease the land for private use. The Twenty-Fifth Judicial District Court for the Parish of Plaquemines held a contradictory hearing and granted the motion, finding the expropriation unconstitutional since the property would be used exclusively by Venture Global and not by the public port. The Louisiana Court of Appeal, Fourth Circuit, reviewed the decision and affirmed, concluding the port authority did not meet the public purpose requirement set by the Louisiana Constitution.The Supreme Court of Louisiana granted certiorari to address whether a public port authority may lawfully expropriate property for leasing to a private entity. The court held that such a taking, when the property is to be used predominantly by a private company, does not constitute a public purpose as defined in the Louisiana Constitution. The court affirmed the lower courts’ rulings, finding the expropriation prohibited and the motion to dismiss properly granted. View "PLAQUEMINES PORT HARBOR & TERMINAL DISTRICT VS. NGUYEN" on Justia Law

Koch Methanol St. James, LLC sought approval from St. James Parish for a land use permit to upgrade its methanol production facility, including the installation of a connecting pipeline that would traverse a wetlands area. The Parish’s Land Use Plan includes specific provisions for allowable uses in wetlands, stating that such areas should remain unoccupied except for unique situations requiring a location in the water. The Parish Planning Commission interpreted this language as permitting Koch’s project under Tier 2 review, since the pipeline was considered a unique situation due to its necessity in connecting to an existing pipeline already located in the wetlands.After the Planning Commission approved the application, plaintiffs appealed to the Parish Council, which unanimously rejected the appeal. Plaintiffs then sought judicial review in the District Court for St. James Parish. The district court upheld the Council’s decision, finding that the Parish’s interpretation of the Plan was reasonable, the process was not arbitrary or capricious, and that Tier 2 review was appropriate for the project. The court also noted that the procedures followed were adequate and left room for reasonable differences of opinion.On appeal, the Louisiana Court of Appeal, Fifth Circuit, reversed the district court’s ruling, applying what it termed “de novo review.” The appellate court determined that the Plan required Tier 3 review for any use in wetlands unless specifically listed as allowable, and concluded that the Parish had failed to follow its own ordinance by applying Tier 2 review. The appellate court remanded the matter for further proceedings.The Supreme Court of Louisiana held that the appellate court erred by applying a de novo standard rather than the proper arbitrary and capricious standard of review. The Supreme Court vacated the appellate court’s ruling and reinstated the district court’s judgment, emphasizing deference to the Parish’s interpretation and decision-making authority in land use matters. View "ALEXANDER VS. ST. JAMES PARISH" on Justia Law

The plaintiffs purchased undeveloped property in Westerly, Rhode Island, in 1999. In 2007, they applied to the Rhode Island Department of Environmental Management (DEM) for permission to install an onsite wastewater treatment system (OWTS), a prerequisite for building a residence on their land. DEM denied their application because the groundwater table on the property was only five inches below the surface, while regulations required a minimum of twelve inches. The plaintiffs did not pursue an administrative appeal at that time.In 2020, more than a decade after the denial, the plaintiffs filed suit in Washington County Superior Court, seeking declaratory relief and compensation for an alleged regulatory taking under state and federal law. They also asserted that the regulation violated their rights to equal protection and due process. The state moved to dismiss the action, contending it was time-barred, the plaintiffs failed to exhaust administrative remedies, and they lacked standing. The Superior Court agreed, holding that the claims were barred by the statute of limitations, that administrative remedies had not been exhausted, and that the plaintiffs lacked standing. The court dismissed the case with prejudice.On appeal, the Supreme Court of Rhode Island reviewed whether the lower court’s dismissal was proper. The Court held that the three-year statute of limitations applied to all claims, and the continuing violation doctrine did not toll the limitations period because DEM’s denial of the permit was a discrete act, not a continuing violation. The Court further found the plaintiffs lacked standing for prospective relief because they did not allege an actual or imminent injury, as any future application might not necessarily be denied. The Supreme Court of Rhode Island affirmed the judgment of the Superior Court. View "Majeika v. State of Rhode Island" on Justia Law

The dispute centers on a series of complex financial transactions involving a Wyoming family and their businesses, a local bank, and a commercial lender. The plaintiffs, including a married couple and their closely held LLC, entered into various loans and mortgages related to their commercial property and business operations. When financial difficulties arose—exacerbated by a downturn in the oil and gas industry—the parties restructured their debt, resulting in a 2017 mortgage and, after the operating company filed for bankruptcy, a 2019 settlement agreement. The plaintiffs later alleged that the bank and lender’s actions and omissions caused them to lose equity in both their home and commercial property, and the defendants counterclaimed for breach of the settlement agreement and sought attorney fees.The District Court of Natrona County dismissed or granted summary judgment for the bank and lender on all claims and counterclaims, finding the mortgage unambiguously secured two loans and the bank had no duty to release it after only one was repaid. It also concluded the plaintiffs could not establish justifiable reliance on any alleged misrepresentations, interpreted the settlement agreement as permitting (but not requiring) the lender to record the quitclaim deed after a sale period, and found no breach by the lender. The district court further ruled the plaintiffs breached the agreement by filing suit, thus entitling the bank and lender to attorney fees.On review, the Supreme Court of Wyoming affirmed the district court’s decisions dismissing the plaintiffs’ claims, holding the mortgage secured both loans and the bank acted within its rights. The Supreme Court, however, reversed the grant of summary judgment to the bank and lender on their counterclaims, finding that filing the lawsuit was not a breach of the settlement agreement or its implied covenant of good faith and fair dealing. Consequently, the award of attorney fees and costs to the bank and lender was also reversed. View "Adams v. ANB Bank" on Justia Law

The appellants, including trustees of several trusts and Hall Atlas, LLC, held coal mining rights to the Hall Ranch in Wyoming, containing significant coal reserves. In 1985, the Wyoming Department of Environmental Quality (WDEQ) determined that a portion of the Hall Ranch was located on an alluvial valley floor (AVF), which limited mining under the Surface Mining Control and Reclamation Act (SMCRA). For decades, neither the appellants nor Exxon Coal Resources, the lessee at the time, pursued a coal exchange. In 2010, Hall Atlas applied to the Bureau of Land Management (BLM) for a coal exchange. BLM initially rejected WDEQ’s 1985 determination but changed position in 2014, and Hall Atlas submitted a mine plan. In 2016, BLM determined the Hall Ranch AVF coal had a value of $0. In 2017, BLM reiterated its $0 valuation and rejected the appellants’ proposed exchange tract, instead proposing alternatives based on the same valuation.The United States Court of Federal Claims dismissed the appellants’ takings claim for lack of subject matter jurisdiction, holding that the claim was time-barred because it was filed more than six years after the claim accrued. The appellants argued that their claim did not accrue until BLM’s 2017 letter, but the court found that the relevant accrual date was in 2016, when BLM finalized its $0 valuation.On appeal, the United States Court of Appeals for the Federal Circuit affirmed the decision. The Federal Circuit held that any takings claim accrued no later than 2016, making the 2023 filing untimely under the Tucker Act’s six-year statute of limitations. The court rejected arguments for equitable tolling and the application of the continuing claim or stabilization doctrines, and concluded the dismissal for lack of subject matter jurisdiction was correct. The judgment was affirmed and costs were awarded to the appellee. View "WYOMING TRUST CO. v. US " on Justia Law

After both parents contracted COVID-19 in 2020, they asked their daughter to move from Tennessee to Alabama to care for them. In exchange for her agreement to relocate and provide care, the parents promised to convey an interest in their Orange Beach condominium to the daughter. The parents, acting in their individual capacities, executed a deed purporting to transfer an interest in the property to themselves and their daughter as joint tenants. The daughter was not aware that the condominium was, in fact, owned by a revocable trust for which the parents served as trustees.The parents later sought to annul the deed in the Baldwin Circuit Court, arguing that the deed was ineffective because the property was owned by the trust and they had not executed the deed as trustees. They also contended that the conveyance was voidable under Alabama law because a material part of the consideration was the daughter’s promise to support them. The daughter sought reformation of the deed to reflect the parents' trustee status and counterclaimed for fraud and breach of warranty. The Baldwin Circuit Court annulled the deed and dismissed the daughter’s counterclaims.The Supreme Court of Alabama reviewed the case. It held that the controlling statute, § 8-9-12, Ala. Code 1975, permitted annulment of a real property conveyance when a material part of the consideration was an agreement to provide support, regardless of whether the grantor acted as an individual or trustee. The Court further held that annulment of the deed extinguished any warranties arising from the conveyance and rendered the fraud counterclaim untenable. Accordingly, the Supreme Court of Alabama affirmed the judgment, upholding annulment of the deed and dismissal of the counterclaims. View "Schumpert v. Wallace" on Justia Law

Fifteen local United Methodist Church congregations in Alabama initiated civil actions against the Alabama-West Florida Conference of the United Methodist Church, Inc., seeking to quiet title to the church properties they occupied and used for worship. The Conference and its board of trustees joined the cases and filed counterclaims, asserting that the properties were either owned by the Conference’s board or held by the local churches in trust for the Conference or its board. Both sides relied primarily on secular documents, such as deeds and corporate records, though the Conference also referenced trust provisions in the Book of Discipline.Trial courts in various counties reviewed the motions by the local churches to dismiss the Conference’s counterclaims, arguing that the courts lacked subject-matter jurisdiction under the ecclesiastical-abstention doctrine, which prohibits courts from resolving matters of church doctrine or internal governance. The trial courts granted the motions to dismiss the counterclaims but allowed the local churches’ quiet-title claims to proceed. The Conference and its board then petitioned the Supreme Court of Alabama for writs of mandamus, seeking to overturn the dismissals.The Supreme Court of Alabama determined that the trial courts erred in dismissing the counterclaims for lack of subject-matter jurisdiction. The Court held that the property disputes could be resolved under neutral principles of law without requiring the courts to decide ecclesiastical matters. Because both parties relied on the same secular materials, and the counterclaims did not require adjudication of religious doctrine, the ecclesiastical-abstention doctrine did not bar jurisdiction. The Supreme Court issued writs of mandamus, directing the trial courts to vacate their orders dismissing the Conference’s counterclaims. View "Mt. Zion of Autauga County, Inc. v. Alabama-West Florida Conference of the United Methodist Church, Inc." on Justia Law