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JeanneK3 (Maryland)
Posts: 562
Posted:
Hello.
I just found out that California's Davis-Stirling Act prohibits the filing of liens for unpaid fines. Are there any other states that do the same?
Thanks.
Jeanne
DonnaS (Tennessee)
Posts: 5,671
Posted:

Jeanne,

Florida! HOAs, Condos and Mobile Home associations. All 3 are under different Statutes but include the same restrictions.
BrianB (California)
Posts: 2,820
Posted:
i can't swear to it, but i believe there are other states that also prohibit this practice. it is a backlash after several high profile cases where folks started to lose their homes for nit picking fines and penalties for not responding to those fines (ie, politicians decided they didn't want people to lose their home because they had weeds, some gravel in the driveway, broken window pane, etc.).

You can still lien for failure to pay contractual assessments, but in Cali, not for failing to pay a fine.
MaryA1 (Arizona)
Posts: 7,043
Posted:
In AZ, the HOA can file a lien for unpaid fines and can also obtain a judgement; however, the judgement cannot be collected until the property changes ownership.

Could you please reference the Davis-Stirling provision that states a lien cannot be filed to collect unpaid fines? I could only find the following provision which only says the covenants may be enforced and that the prevailing pary shall be awarded reasonable attorney's fees and costs. It doesn't say whether or not a fine can be imposed or whether or not a lien may be filed to collect those fines. Actually it really leaves the issue of fines hanging! Elsewhere in the Davis-Stirling Act it only talks about assessment liens.

Civil Code §1354. Enforcement Rights, Attorneys' Fees

(a) The covenants and restrictions in the declaration shall be enforceable equitable servitudes, unless unreasonable, and shall inure to the benefit of and bind all owners of separate interests in the development. Unless the declaration states otherwise, these servitudes may be enforced by any owner of a separate interest or by the association, or by both.

(b) A governing document other than the declaration may be enforced by the association against an owner of a separate interest or by an owner of a separate interest against the association.

(c) In an action to enforce the governing documents, the prevailing party shall be awarded reasonable attorney's fees and costs.

JeanneK3 (Maryland)
Posts: 562
Posted:
Mary-Try Civil Code 1367.1e. Actually, (c) the section you sent me is very useful in that there are Maryland attorneys that make everything in the bylaws that for any action the homeowner pays both his and the board's legal fees. Can you believe it?
Jeanne
MaryA1 (Arizona)
Posts: 7,043
Posted:
Jeanne,

It's not uncommon for the attorney fees and collection costs to be passed on to the member, and rightly so. However, I don't believe the BOD's legal fees should be passed on except by a Judge.

DonnaS (Tennessee)
Posts: 5,671
Posted:

Mary,

In Florida, the Statutes state that the "prevailing party" may collect reasonable costs, whatever reasonable means.

From 720:311-- "and the prevailing party in an arbitration proceeding shall recover its reasonable costs and attorney's fees in an amount found reasonable by the arbitrator.

From 720, 305---The court shall award the prevailing party reasonable attorney's fees and costs incurred in connection with a claim that an action was filed in violation of this section

Boards are entitled to collect fees from members who lose cases against the HOA.
RobertG (Arizona)
Posts: 505
Posted:
Quote:
Posted By MaryA1 on 07/13/2009 11:01 AM
In AZ, the HOA can file a lien for unpaid fines and can also obtain a judgement; however, the judgement cannot be collected until the property changes ownership.

Could you please reference the Davis-Stirling provision that states a lien cannot be filed to collect unpaid fines? I could only find the following provision which only says the covenants may be enforced and that the prevailing pary shall be awarded reasonable attorney's fees and costs. It doesn't say whether or not a fine can be imposed or whether or not a lien may be filed to collect those fines. Actually it really leaves the issue of fines hanging! Elsewhere in the Davis-Stirling Act it only talks about assessment liens.

Civil Code §1354. Enforcement Rights, Attorneys' Fees

(a) The covenants and restrictions in the declaration shall be enforceable equitable servitudes, unless unreasonable, and shall inure to the benefit of and bind all owners of separate interests in the development. Unless the declaration states otherwise, these servitudes may be enforced by any owner of a separate interest or by the association, or by both.

(b) A governing document other than the declaration may be enforced by the association against an owner of a separate interest or by an owner of a separate interest against the association.

(c) In an action to enforce the governing documents, the prevailing party shall be awarded reasonable attorney's fees and costs.


Mary, I don't have a reference for proof, but I think you are mixing fines and assessments. I think what you said for AZ only applies to assessments. I don't think you can place a lien for an unpaid fine.
MaryA1 (Arizona)
Posts: 7,043
Posted:
Robert,

Please read ARS 33-1807, subsection A: "The assn has a lien for fees, charges, late charges, other than charges for late payment of assessments, monetary penalties or interest charged pursuant to section 33-1803 after the entry of a judgment in a civil suit for those fees, charges, late charges, monetary penalties or interest from a court of competent jurisdiction and the recording of that judgment in the office of the County recorder as otherwise provided by law. The assn's lien for monies other than for assessments, for charges for late payment of those assessments, for reasonable collection fees and for reasoable attorney fees and costs incurred with repect to those assessments may not be foreclosed and is effective only on conveyance of my interest in the real property." It's quite cumbersome but note that it does say "monetary penalties" (fines).
RobertG (Arizona)
Posts: 505
Posted:
Quote:
Posted By MaryA1 on 07/13/2009 1:59 PM
Robert,

Please read ARS 33-1807, subsection A: "The assn has a lien for fees, charges, late charges, other than charges for late payment of assessments, monetary penalties or interest charged pursuant to section 33-1803 after the entry of a judgment in a civil suit for those fees, charges, late charges, monetary penalties or interest from a court of competent jurisdiction and the recording of that judgment in the office of the County recorder as otherwise provided by law. The assn's lien for monies other than for assessments, for charges for late payment of those assessments, for reasonable collection fees and for reasoable attorney fees and costs incurred with repect to those assessments may not be foreclosed and is effective only on conveyance of my interest in the real property." It's quite cumbersome but note that it does say "monetary penalties" (fines).

My definition of monetary penalties would be a dollar amount charged for not paying an assessment, not for violating some type of landscape restricting (for example). I see your argument, now I have to figure out why I think I heard what I did.
RobertG (Arizona)
Posts: 505
Posted:
Quote:
Posted By MaryA1 on 07/13/2009 1:59 PM
Robert,

Please read ARS 33-1807, subsection A: "The assn has a lien for fees, charges, late charges, other than charges for late payment of assessments, monetary penalties or interest charged pursuant to section 33-1803 after the entry of a judgment in a civil suit for those fees, charges, late charges, monetary penalties or interest from a court of competent jurisdiction and the recording of that judgment in the office of the County recorder as otherwise provided by law. The assn's lien for monies other than for assessments, for charges for late payment of those assessments, for reasonable collection fees and for reasoable attorney fees and costs incurred with repect to those assessments may not be foreclosed and is effective only on conveyance of my interest in the real property." It's quite cumbersome but note that it does say "monetary penalties" (fines).

I think I found what I had heard. The end result is about the same as you say, but for fines there is a big hurdle to jump through to get the lien.

From Jackson White Law, an HOA attorney -

"Lawmakers also took great care in distinguishing liens and foreclosure actions for unpaid assessments from liens and foreclosure action for unpaid fines.

Unlike assessment liens, an association cannot record a lien for unpaid fines until it first sues the homeowner in court and wins. This means any “lien” on a homeowner’s property for unpaid fines without proper court authority may be a “false document” in a violation of Arizona’s false recording laws. It also means the individual director and/or the association responsible for its recording may be liable for statutory damages of at least $5,000.

Importantly, unlike assessment liens, an association cannot evict a homeowner for fine liens. Thus, even if a homeowner is sued for fines and the association wins, the association still cannot foreclose on those fines until the home is sold or the title is transferred."
AnnD1 (California)
Posts: 7
Posted:
Hi Everyone, Received a Notice of Violation from your HOA collection Attorney, to a new potential home owner that is in escrow, stating that the new homeowner has to pay the previous owners landscaping maintance fines, totaling $11000.00 dollars. Now the realtor and homeowner is about to back out of the deal if the board does not come to a decision to release the new homeowner from the debt. The lien was placed but never recorded, therefore the attorney now is trying to collect the debt by having it taken out of the escrow before the potential homeowner can get the home. I never heard of this and can not find it in the codes. The attorney is using Civil Code 1102.6 but that seems to me to answer to assessment dues, special assessment dues, mella roos, and taxes. Does anyone know of anything in the Davis Sterling Act that speaks to this?
MaryA1 (Arizona)
Posts: 7,043
Posted:
Ann,

If the lien was never recorded, IMO, it doesn't exist. Does this h/o actually owe the assn $11,000 in fines? Why is this attorney taking this action w/o board approval? What do your CCRs say about passing debts to a succeeding owner? Some assn CCRs state unpaid assessments will be the resp. of the new owner.

Sorry, Ann, but I think we need a lot more info from you including whether or not you are a board member.

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