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Stillwaters Residential Ass'n v. SW Properties, LLC

Citations: 137 So. 3d 931; 2013 Ala. Civ. App. LEXIS 145; 2013 WL 3242833Docket: 2120456

Court: Court of Civil Appeals of Alabama; June 28, 2013; Alabama; State Appellate Court

Narrative Opinion Summary

This case involves a property dispute where SW Properties, LLC sought to reform a deed in Tallapoosa County, originally acquired from Still Waters Development Co. LTD Partnership, on grounds that it incorrectly subjected the property to certain subdivision covenants. The court granted a default judgment in favor of SW Properties when Still Waters failed to respond. Subsequently, StillWaters Residential Association, Inc. attempted to intervene, asserting an interest in the property due to unpaid fees and covenants, but their motions were not addressed by the trial court. The association appealed the default judgment, claiming it was a necessary party to the action. However, because the trial court had not ruled on the association’s motion to intervene, the appeal was dismissed as premature. The court highlighted that a nonparty to a case, such as the association, lacks standing to appeal decisions in actions between other parties. The ruling emphasized that intervention must be resolved for an appeal to proceed, leading to the dismissal of the association's appeal. The court's decision was concurred by Judges Thompson, Pittman, and Donaldson, with Judge Moore concurring in result without a separate opinion.

Legal Issues Addressed

Appeal of Denial of Motion to Intervene

Application: The appeal was deemed premature as the trial court had not ruled on the motion to intervene, which must be definitively resolved for appealability.

Reasoning: The court found no record of the trial court ruling on the association’s motion to intervene, indicating it remains pending.

Intervention in Litigation

Application: StillWaters Residential Association, Inc. attempted to intervene, claiming an interest in the property, but the trial court did not address the motion, leaving the intervention unresolved.

Reasoning: The association later moved to vacate the default judgment, stating it was unaware of the judgment when it intervened, but the trial court did not address either motion.

Reformation of Deed

Application: The court granted a default judgment to reform the deed when the defendant failed to respond to the petition filed by SW Properties, LLC.

Reasoning: SW Properties filed a motion for a hearing, and on October 23, 2012, after SW Development failed to respond, the court granted a default judgment for reformation of the deed.

Standing to Appeal

Application: The association lacked standing to appeal as it was not a party to the underlying action due to the unresolved intervention motion.

Reasoning: In this case, the association, not being a party to the underlying action, lacked standing to file a motion to vacate the trial court's judgment from October 23, 2012, and also lacks standing to appeal the denial of that motion.