Seaview Ass'n of Fire Island, Inc. v. Williams
69 N.Y.2d 987 (1987)
Rule of Law:
Purchasing property within a private community with knowledge that a homeowners' association provides facilities and services for the benefit of all residents creates an implied-in-fact contract, obligating the owner to pay a proportionate share of the association's costs.
Facts:
- Seaview Association of Fire Island, N. Y., Inc. (Plaintiff) is a homeowners' association for Seaview, an unincorporated Fire Island community with approximately 330 homes.
- The association owns and maintains the community's streets, walkways, beaches, and provides various services and recreational facilities.
- All Seaview property owners are assessed a share of the association's annual operating costs.
- Renee Roth and her family (Defendants) lived in an adjoining community before purchasing their first house in Seaview in 1963.
- Over time, the Roths purchased a total of seven houses in Seaview.
- The Roths' property deeds include easements granting them the use of the community's ocean beaches and walkways.
- The Roths, who are among the only year-round residents, refused to pay any of the association's assessments levied between 1976 and 1984.
- They contended they were not obligated to pay because they were not members of the association and did not use the recreational facilities it maintained.
Procedural Posture:
- Seaview Association of Fire Island, N. Y., Inc. sued Renee Roth et al. in a New York trial court to recover unpaid assessments for the years 1976 through 1984.
- Following a five-day bench trial, the trial court entered a judgment for the plaintiff, Seaview Association.
- The defendants, Renee Roth et al., appealed the trial court's judgment to the Appellate Division of the Supreme Court of New York, an intermediate appellate court.
- The Appellate Division affirmed the trial court's decision, with one justice dissenting.
- The Appellate Division then granted the defendants (appellants) leave to appeal to the Court of Appeals of the State of New York, the state's highest court.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does the purchase of property within a private community, with knowledge that a homeowners' association provides services and facilities for all residents, create an implied-in-fact contract obligating the purchaser to pay a proportionate share of the association's costs, regardless of their formal membership or use of all facilities?
Opinions:
Majority - Per Curiam
Yes. The purchase of property within a private community with knowledge of the association's services creates an implied-in-fact contract to pay assessments. Where there is knowledge that a private homeowners' association provides facilities and services for the benefit of community residents, the act of purchasing property there manifests an acceptance of the conditions of ownership, which includes the obligation to pay for the facilities and services offered. This resulting implied-in-fact contract obligates the owner to pay a proportionate share of the full cost of maintaining those facilities and services, not merely the reasonable value of those they actually use. The court determined that the lower courts' factual findings—that the defendants had actual or constructive knowledge of the community's nature and the conditions of ownership—were amply supported by the evidence and thus beyond its review.
Analysis:
This decision solidifies the legal standing of homeowners' associations in New York to compel payment from all property owners within their jurisdiction, even non-members, based on an implied-in-fact contract theory. It prevents a 'free-rider' problem where residents could benefit from community-wide services (like maintained roads and beaches) while refusing to pay for them by claiming non-use of specific recreational amenities. The ruling emphasizes that knowledge at the time of purchase is the key element in creating this payment obligation, thereby providing financial stability and enforcement power to planned communities.
Gunnerbot
AI-powered case assistant
Loaded: Seaview Ass'n of Fire Island, Inc. v. Williams (1987)
Try: "What was the holding?" or "Explain the dissent"