Millbrook Hunt, Inc. v. Smith

Rule of Law:

A homeowners association's duties are strictly limited by its governing documents, and duties not explicitly stated or reasonably inferred will not be imposed by a court. Furthermore, a corporate officer cannot be held personally liable for the corporation's actions unless a plaintiff provides sufficient evidence to pierce the corporate veil.

Facts:

• Alfred Barone was the president of the corporation that constructed a town house development.
• The Coventry Homeowners Association, Inc. (Coventry) governed the development, and its responsibilities were detailed in an offering plan.
• Approximately six years after construction, ten-year-old Joshua Eagle resided in one of the town houses with his parents, Leonard and Jacqueline Eagle.
• While Joshua Eagle was climbing on the brick facade of his family's town house, the facade detached from the building.
• The detached facade collapsed on top of Joshua Eagle, causing his death.

Procedural Posture:

• The decedent's representative filed two wrongful death actions in the Supreme Court of Suffolk County, a New York trial court.
• Action No. 1 was filed against Coventry Homeowners Association, Inc. (Coventry).
• Action No. 2 was filed against Alfred Barone.
• In Action No. 1, Coventry filed a third-party complaint against the decedent's parents, Leonard Mark Eagle and Jacqueline Eagle.
• Coventry, Barone, and the Eagles each moved for summary judgment in the trial court.
• The trial court granted summary judgment to Coventry, dismissing the complaint against it.
• The trial court granted summary judgment to Barone, dismissing the complaint against him, and a final judgment was entered in his favor.
• The trial court also granted summary judgment to the Eagles, dismissing Coventry's third-party complaint.
• The plaintiff (appellant) appealed the trial court's orders granting summary judgment in favor of Coventry and Barone to the Appellate Division of the Supreme Court.