Windham Land Trust v. Jeffords
967 A.2d 690, 2009 ME 29 (2009)
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Rule of Law:
When interpreting a deed, words are given their common and ordinary meaning. The term 'residential recreational purposes' in a conservation easement deed unambiguously restricts the use of the protected property to recreational activities by its residents and prohibits commercial, income-generating activities offered to the paying public.
Facts:
- In 2003, the Freeman Estate donated a conservation easement on an 85-acre portion of its 100-acre farm (the 'Protected Parcel') to the Windham Land Trust.
- The easement deed stated its dominant purpose was to preserve the land's natural features while allowing the property to be used for 'residential recreational purposes'.
- In 2004, Russell Jeffords and Susan Poulin (the Owners) purchased the farm and expressly agreed to be bound by the conservation easement.
- The Owners planned to use the Protected Parcel for various commercial activities offered to their 'paying guests,' including wagon rides, sleigh rides, hiking, snowshoeing, skiing, fishing, and ice skating.
- The Owners claimed they could not afford to maintain the trails and pond on the Protected Parcel without generating income from these commercial activities.
- The easement deed contained a clause requiring the parties to engage in good faith mediation as a precondition to commencing any court action.
- In November 2006, the Windham Land Trust contacted the Owners to schedule the required mediation, but the Owners refused to participate within the proposed timeframe.
Procedural Posture:
- The Windham Land Trust filed a complaint against the Owners (Jeffords and Poulin) in the Maine Superior Court, seeking a declaratory judgment and injunctive relief.
- The trial court granted the Trust's motion for a preliminary injunction.
- The State of Maine's motion to intervene on behalf of the Trust was granted by the court.
- The Owners filed a motion to dismiss the complaints, arguing the court lacked subject matter jurisdiction because the contractually required pre-litigation mediation did not occur.
- The trial court denied the Owners' motion to dismiss.
- The Trust and the State filed a joint motion for summary judgment, which the trial court granted.
- The trial court also issued a permanent injunction prohibiting the Owners from conducting their proposed commercial activities on the Protected Parcel.
- The Owners (appellants) appealed the summary judgment and permanent injunction to the Supreme Judicial Court of Maine.
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Issue:
Does a conservation easement that limits land use to 'residential recreational purposes' prohibit the landowners from offering income-generating recreational activities, such as horse-drawn sleigh rides and skiing, to the paying public?
Opinions:
Majority - Alexander, J.
Yes, the conservation easement prohibits the landowners from offering income-generating recreational activities to the paying public. The court must interpret a deed by looking at the plain language within its four corners, giving words their common and everyday meaning. The word 'residential' relates to a residence or those living there. Therefore, 'residential recreational purposes' unambiguously refers to recreational activities for the private use of the residents of the property, not for commercial ventures open to the public. This interpretation is consistent with the deed's overall stated purpose to preserve the land's 'natural, open space, scenic, aesthetic and ecological features.' The court rejected the Owners' attempt to introduce extrinsic evidence because the deed's language was not ambiguous. The Owners' equitable estoppel argument also failed as they did not demonstrate any detrimental reliance on alleged statements by the Trust’s attorney.
Analysis:
This decision reinforces the legal principle that unambiguous terms in a deed will be enforced according to their plain and ordinary meaning, without resort to outside evidence. It establishes a strong precedent for land trusts by narrowly defining 'residential recreational purposes' to exclude commercial activities, thereby protecting the conservation goals of easements. The ruling makes it more difficult for subsequent landowners to introduce commercial uses on protected land by arguing for a broader interpretation of the deed's language, thus strengthening the perpetual nature of conservation restrictions.
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