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Hueg v. Sunburst Farms (Glendale) Mutual Water & Agricultural Co.

Citations: 122 Ariz. 284; 594 P.2d 538; 1979 Ariz. App. LEXIS 450Docket: No. 1 CA-CIV 3738

Court: Court of Appeals of Arizona; March 6, 1979; Arizona; State Appellate Court

Narrative Opinion Summary

This case involves homeowners challenging the enforceability of mandatory membership and payment obligations to a water and agricultural company imposed by recorded covenants. The appellants, homeowners in two subdivisions, sought a declaratory judgment to invalidate these covenants following unsuccessful attempts to revoke them through majority-signed petitions. The trial court denied their request, ruling that the petitions to revoke were ineffective due to insufficient valid signatures, a decision later affirmed on appeal. The appellate court emphasized that the acceptance of a deed incorporates its terms, thereby binding homeowners to pre-existing covenants despite any prior agreements. The court also addressed the automatic nature of Association membership and the accompanying responsibilities, including the payment of charges that, if unpaid, result in a lien on the property. The judgment affirmed the enforceability of the covenants, with no findings required on the part of the trial court, and upheld the validity of the liens for unpaid charges as permissible under the covenants and Arizona law. The case highlights the complexities of covenant enforcement and the legal standards required for revocation efforts to succeed.

Legal Issues Addressed

Automatic Membership and Obligations under Covenants

Application: Members are automatically part of the Association and are liable for charges imposed by the Board of Directors, with no right to exempt themselves through waivers.

Reasoning: Members are fully liable for charges set by the Board of Directors related to irrigation water, tillage of project lands, and other associated services, with no right to exempt themselves through waivers or abandonment of their units.

Enforceability of Covenants upon Deed Acceptance

Application: The court held that the acceptance of a deed incorporates the terms of the deed into the agreement, superseding prior agreements and thus binding the homeowners to the covenants.

Reasoning: The acceptance of a deed incorporates the terms of the deed into the agreement, thus superseding prior agreements.

Lien Creation for Unpaid Charges

Application: Unpaid charges create a lien on the member's lot, accruing interest, which is subordinate to any first mortgage lien.

Reasoning: If charges remain unpaid beyond the established deadline, they will be considered delinquent and will create a lien on the member's lot, accruing interest at 5% per annum until paid.

Revocation of Recorded Covenants and Restrictions

Application: The court found the petitions to revoke covenants ineffective due to insufficient valid signatures from a majority of lot owners as required by the declarations.

Reasoning: The trial court impliedly found that the petitions lacked valid signatures from a majority of lot owners in subdivisions 19 and 20, concluding they did not meet the 'majority vote' requirement of Article IV, Section 3 of the Declarations.