Goudreau v. Pine Springs Road & Water, LLC
2012 ME 70
| Me. | 2012Background
- In 1967-1968, Pine Springs conveyed land to Pine Springs Development Corp. and subdivision plans were recorded.
- Lot Owners purchased lots with deeds referencing subdivision lots and rights of way over private roads for access to the public highway.
- Town of Shapleigh did not accept the subdivision roads; roads remain privately owned and PSRW claims ownership.
- 1968 minutes purportedly imposed covenants, including a $100 annual maintenance fee running with the land until 1980, for road-related benefits.
- 1968 minutes, 1988 Lake Association minutes, 1997 Extension, and later transfers attempted to impose or extend maintenance obligations; subsequent events affected enforceability.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Lot Owners may form a statutory road association under 23 M.R.S. § 3101. | Goudreau arguing parcels are benefited by easements and roads are private roads. | PSRW/pine springs contending roads are not appropriately defined as private roads/associations under §3101. | Yes; Lot Owners may form a road association because roads are private roads and each parcel is benefited by easements. |
| Whether the maintenance-fee covenant obligates Lot Owners to pay when the sunset provision expired in 1980. | Covenants extend or revive the obligation beyond 1980. | Sunset provision extinguishes the obligation after 1980; extensions invalid. | Obligation expired on December 31, 1980; neither Lake Association minutes nor 1997 Extension bind the Lot Owners. |
Key Cases Cited
- Peters v. O'Leary, 2011 ME 106 (Me. 2011) (statutory interpretation and de novo review of questions of law cores)
- Matteson v. Batchelder, 2011 ME 134 (Me. 2011) (de novo review; easements and rights of way in deeds)
- Silsby v. Belch, 2008 ME 104 (Me. 2008) (contract interpretation and covenants running with land)
- Murch v. Nash, 2004 ME 139 (Me. 2004) (right-of-way and subdivision plan implications)
