I cannot agree. Best Practices for Getting Your Homeowners Association through Difficult Economic Times, Texas Department of Housing and Community Affairs v. The Inclusive Communities Project, The Supreme Court's New Disparate Impact Case: What It Means to HOAs, Rentals in Your HOA or Condo Getting You Down? Between 1984 and 1991, several transfers of development rights and amendments to the covenants were recorded, the validity of which was not questioned and which are not relevant to our analysis in this case. However, after May 9, 2019, unless the member has consented as provided by subsection (1), a homeowners' association may not enforce a covenant, condition, or restriction in such a way that limits the types of use of a member's real property that were allowed when the member acquired the affected real property. C=T/;^PFgLzb"gYv_hnktx*? Montana's Judicial Branch seeks to provide equal access to justice while building the public's trust and confidence in Montana courts. See Newman, 277 Mont. 17In Boyles, the original covenants allowed for changes to [t]hese covenants, water use regulations, restrictions and conditions if a majority of the then owners agreed to change same in whole or in part. Boyles, 517 N.W.2d at 616. (5)Nothing in this section invalidates existing covenants of a homeowners' association or creates a private right of action for actions or omissions occurring before May 9, 2019. This Amendment was approved by 74 percent of the owners of lots 6, 7, and 9 through 15 of COS 1131, and purports to modify the covenants and restrictions applicable to those lots. The library is located in the Joseph P. Mazurek Justice Building at 215 N. Sanders in Helena, Montana. 53. Supreme Court of Montana. 201, 208-09, 536 P.2d 1185, 1189-90. You probably already know that under the federal Fair Housing Act, it's unlawful to refuse to sell or rent housing on the basis of race or another protected class and to do the same in certain real estate transactions. That was the argument the ICP made in the Texas casethat the DHCA's distribution of the credits was, on its face, racially neutral, but that statistics proved the distribution resulted in harm to minorities. See also Toavs v. Sayre (1997), 281 Mont. The Montana Unit Ownership Act (Condominiums) regulates the creation, operation, authority, and management of condominium associations in the state. You're all set! 201, 208-09, 536 P.2d 1185, 1189, that restrictive covenants should not be extended by implication or enlarged by construction and, in Jarrett v. Valley Park, Inc. (1996), 277 Mont. While some would argue that such rulings negate the purpose of having an HOA and neighborhood covenants, homeowners are not without recourse. 7The parties stipulated that all parties to this lawsuit own or have owned, during times pertinent to this action, residential real estate in Missoula County, Montana, and described on Certificate of Survey (COS) 1131. The Supreme Court affirmed the judgment of the district court granting Defendants summary judgment and concluding that Elk Valley Road burdened Lots 70 and 71 to the benefit of other subdivision lot owners for ingress and agree to and from the adjoining off-plat land and concluding that Plaintiffs had no right to obstruct Elk Valley Road. (4)Nothing in this section may be construed to prevent the enforcement of a covenant, condition, or restriction limiting the types of use of a member's real property as long as the covenant, condition, or restriction applied to the real property at the time the member acquired the member's interest in the real property. IN THE SUPREME COURT OF THE STATE OF MONTANA 2016 MT 13N HARBOR VILLAGE HOMEOWNERS ASSOCIATION, INC., a Montana Corporation, Petitioner and Appellee, v. SAM WALDENBERG and SHIRLEEN WEESE, individually and as Trustees of the S&SW TRUST, Respondents and Appellants. APPEAL FROM: District Court of the Eleventh Judicial District, This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply. (2)A successor-in-interest to a member's real property may not claim the benefit of subsection (1) to the extent that the homeowners' association entered into, amended, or enforced a covenant, condition, or restriction before the successor-in-interest purchased the real property, even if the covenant, condition, or restriction was not enforceable against the previous owner pursuant to subsection (1), unless the successor-in-interest is owned by or shares ownership with the previous member or unless the successor-in-interest is a lender that acquired the real property through foreclosure. Get free summaries of new Montana Supreme Court opinions delivered to your inbox! For purposes of reciprocal summary judgment motions, the parties stipulated to a written set of agreed facts. FTXs collapse and the push for centralized regulation of digital assets in the U.S. Are we about to see the rise of the right to earn a living? Court Rules: Court rules explain the procedure to be followed in various courts, including what proper format for paperwork you submit, how to schedule hearings, and how hearings and trials will proceed. The member will be responsible for any filing fees. Notice for member meetings must be provided at least 10 days, but no more than 60 days, before the meeting takes place. This Supreme Court Decision Could Af . The court held that this grant of amendatory power did not give the majority authority to adopt a new covenant prohibiting building within 120 feet of the county road which ran through the subdivision-a use not previously restricted. This exception expires, though, when the real property is sold. Alternatively, they may also file a lawsuit in state or federal court. These needs and obligations are met, in part, through various Boards and Commissions, including: Sentence Review Division, Commission on Rules of Evidence, Access to Justice Commission and Gender Fairness Commission. In coming to this conclusion, the Court relied heavily on its past decisions. Boyles, 517 N.W.2d at 616. Homeowners' association restrictions -- real property rights. IN THE SUPREME COURT OF THE STATE OF MONTANA 2020 MT195 ELK GROVE DEVELOPMENT COMPANY, Plaintiff and Appellee, v. FOUR CORNERS COUNTYWATER AND SEWER DISTRICT, Defendant and Appellant, ELK GROVE HOMEOWNERS ASSOCIATION, INC., a Montana Non-Profit Corporation, Intervenor and Appellee. 25The District Court's statement may have intuitive appeal, but it has little support in the stipulated facts or in the text of the 1997 Amendment. %K9\>g(,s\P_s]~B}RN8u 146, 69 P.3d 225; Watson, 33; Waters . The covenant language used in all three cases is markedly different from that used here. 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In Lakeland, the provision permitting the change of covenants: [C]learly directs itself to changes of existing covenants, not the adding of new covenants which have no relation to existing ones. Most homeowners and condominium associations establish themselves as non-profit corporations. The premises, improvements and appurtenances shall be maintained in a safe, neat, clean and orderly condition. TIPS FOR NAVIGATING THIS PAGE This page categorizes court rules as outlined below. A question remains as to whether a homeowner would have standing to sue a neighbor for violation of a covenant when that violation did not cause direct damage to the homeowner. 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Tekoh: The Supreme Court Rules that a Violation of Miranda Rights Alone Does Not Give Rise to Damages Under 42 U.S.C. A court may be governed by several different sets of rules. Eagar, 322 Mich. App. Worse, this case will open the door to allowing majority property owners in a subdivision to violate restrictive covenants covering the subdivision and, concomitantly, to abridge the reasonable and justifiable expectations and rights of minority property owners whenever and for no other reason than that the majority determine that it is in its best interest to do so. (3)This section does not apply to a covenant, condition, or restriction: (a)that is not subject to enforcement by a homeowners' association; or. 19Appellants' observations are correct, to a point. But efforts to alter how judges reach the bench aren't over. 31. If notice is sent out via mail, at least 30 days notice is required. The interim justice then must run in the next general election after they have been appointed to stay on the Court. It is important to read and understand all community regulations before purchasing property in an HOA-managed community. According to this bill, HOAs may not compel homeowners to follow more onerous restrictions than the ones that already existed prior to their purchase of the real property. Since there are no formal regulations regarding HOAs specifically, community rules can vary drastically. (d)"Real property" has the meaning provided in 70-1-106, except that it is limited to real property governed by a homeowners' association. Accord Fox Farm Estates Landowners v. Kreisch (1997), 285 Mont. Find out how in our new article, The Supreme Court's New Disparate Impact Case: What It Means to HOAs. This page features various orders issued by the Montana Supreme Court involving such rules and oversight which are met, in part, through various Boards and Commissions. A court may be governed by several different sets of rules. Newman v. Wittmer (1996), 277 Mont. Holders of over 65 percent of the acreage within lots 1 through 7 and 9 through 15 approved the changes, and thus validly modified the covenants. Instead, most HOAs are set up as nonprofit organizations and are therefore subject to the Montana Nonprofit Corporation Act. 21We conclude that Appellants' reliance upon Lakeland, Caughlin, and Boyles is misplaced. The Montana Supreme Court also holds original jurisdiction over writs of habeas corpus and cases that have not yet reached the district courts in which the dispute is entirely legal rather than factual. 13Restrictive covenants are construed under the same rules as are other contracts: courts read declarations of covenants on their four corners as a whole and terms are construed in their ordinary or popular sense. 37Applying all of the above-referenced interpretational rules to this restrictive covenant, I conclude that the plain and unambiguous language of the covenant limits the waiver, abandonment, termination, modification, alteration or changing of any covenant, condition, restriction and use to those created and established in the original declaration of restrictive covenants. It also contains provisions concerning reasonable accommodations and the need for service animals. Kentucky federal court considers questions of intent under different parts of an insurance policy, Georgia Governor Reinstitutes Non-Party Apportionment, Changing Tides: WOTUS and the Jurisdiction of the Clean Water Act. Decisions from an ALJ can only be enforced via contempt of court heard in Superior Court. Therefore, they are bound by this Act. It provides no protection whatsoever; it is worthless. Unless otherwise stated in the community Covenants, Conditions, and Restrictions (CC&R), each community member is allowed one vote. Get free summaries of new Montana Supreme Court opinions delivered to your inbox! The Appellants are tract owners who neither consented to nor approved the 1997 Amendment. As part of the purchase bargain they rightfully expect that such covenants will not be waived, abandoned, terminated, modified, altered or changed by other property owners except in strict compliance with the provisions of the declaration of covenants themselves or in accordance with supervening statutory law. %K9\>W36!5Bu2=u2P!$Gj#mP]/D7Pzn$j BDB}P?PG.3-+B}cB=5as>9TF'*9edNoqN[kSF The Court must issue each of its decisions in writing, and any justice who dissents from the decision must issue a written dissenting opinion. The court further noted the provision in the original covenants that: No noxious or offensive activity shall be carried on or permitted; nor shall the property be used in any way which may endanger the health, welfare or safety of or unreasonably disturb the occupants of the said real property described herein above. Homeowners have the sole ability to make amendments to governing documents. We affirm. Fund (1994), 266 Mont. The exception is when homeowners provide a written agreement to follow such restrictions at the time they are adopted. For a homeowner to be exempt from new HOA regulations under SB0300, they must request an exemption with the HOA. You can find the Montana Nonprofit Corporation Act under Title 35, Chapter 2 of the Montana Code. This process starts when the Montana Judicial Nominating Commission provides the Governor with a list of three to five nominees. Ahead of a deadline for general policy bills to advance, Montana lawmakers have voted down four different proposals that would have made judicial elections partisan. 33I dissent from the Court's decision as to Issue 1, and would therefore not reach Issue 2 or 3. Nevada's highest court unanimously ruled that a 2014 decision upholding HOAs' ability to foreclose ahead of mortgage lenders can be retroactively applied to foreclosures that took place before that ruling. The amendment which was challenged in Caughlin, however, provided for assessments on new classifications of commercial or recreational property. Appellants McCue and Ronald and Kathleen Perkins have not disputed that they received such copies. The amendment was valid under the contractual provision creating a right to change the covenants by written consent of the owners of 51 percent of the lots in the subdivision. Sign up They further maintain that the 1997 Amendment seeks to create new and substantially different covenants rather than to amend existing covenants. The Connecticut Supreme Court finds that the Litigation Privilege extends to claims of bad faith based upon an insurers actions during litigation. (a) "Homeowners' association" means: (i) an association of all the owners of real property within a geographic area defined by physical boundaries which: (A) is formally governed by a declaration of covenants, bylaws, or both; (B) may be authorized to impose assessments that, if unpaid, may become a lien on a member's real property; and 20In Sunday Canyon Property Owners Association v. Annett (Tex.App.1998), 978 S.W.2d 654, a Texas court of appeals considered restrictive covenant language remarkably similar to the language in the present case. General - Sections 35-2-101 through 35-2-133 22We hold that the language of the original declaration of restrictive covenants was broad enough to authorize the subsequent 1997 Amendment by a super-majority of 65 percent or more of the property owners. He interpreted the HOAs governing documents as providing that right but not making it an obligation. Under the broad powers of amendment discussed above, it is unnecessary that amendments to the restrictive covenants be connected to a provision of the original restrictive covenants. You can find the Montana Unit Ownership Act (Condominiums) under Title 70, Chapter 23 of the Montana Code. APPEAL FROM: District Court of the Eighteenth Judicial District, Bruner v. Yellowstone County (1995), 272 Mont. 1983, Law Firm Ordered to Produce Client Communications Despite the Attorney-Client Privilege and Work-Product Doctrine, Massachusetts high court holds that attorneys fees awarded under G.L. Special meetings may be called in addition to the annual meetings with a signed petition from at least 5% of the voting power. In that respect, it is well_settled that [w]here the language of an agreement is clear and unambiguous and, as a result, susceptible to only one interpretation, the duty of the court is to apply the language as written. Carelli v. Hall (1996), 279 Mont. 70-17-901 Homeowners' association restrictions -- real property rights. Montana Supreme Court Montana's Judicial Branch seeks to provide equal access to justice while building the public's trust and confidence in Montana courts. The Montana Senate must confirm the appointment. In other words, it does not have discretion to decide whether to review a case. In Texas, it's the Department of Housing and Community Affairs that does the distribution. For Legal Professionals. The drafters used universal language to describe the kinds of changes a super-majority of at least 65 percent of the tenants may make: waive [], abandon [], terminate[], modify[], alter[] or change[]. Further, the original covenants clearly provide that every aspect of the covenants, conditions, restrictions and uses is subject to such amendment by a super-majority. 35As noted, restrictive covenants are construed under the same rules as are other contracts. 42. The Governor has 30 days to choose a nominee from this list, or otherwise the Chief Justice of the Supreme Court will make the decision. Judge David Dickinson reached a similar conclusion in the Forsyth County Superior Court case of Lake Astoria Community Association, Inc. v. Ingmire v. Furr where the homeowner sued the HOA for failing to enforce neighborhood covenants consistently. The Supreme Court also reviews appeals from the workers compensation and water courts. 12The parties agree that the question of whether restrictive covenants may be amended to oblige a nonconsenting landowner to new or different use restrictions is a question of first impression in Montana. 333, 341, 922 P.2d 485, 489, we clarified that our meaning was that the district court could not broaden the covenant by adding a limitation not contained therein.. at 238, 649 P.2d at 431. : Why insurance claims professionals should pay attention to Monkeypox, California just enacted new law to increase the wages and standards for fast-food employees and Opponents are already trying to stop it in its tracks, 3rd Circuit finds data leaked on dark web shaming site inferred a substantial risk of imminent harm, Owners and contractors beware: Massachusetts Appeals Court strictly interprets the Prompt Pay Act, Employee or Independent Contractor? This, the Appellants argue, renders the 1997 Amendment invalid as to their properties. The court determined that the Windemere Homeowners Association, Inc., had authority, under a 1997 Amendment to restrictive covenants, to assess against subdivision tract owners the costs of paving a common road. 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These rulings raise the question of whether HOA's can enforce neighborhood covenants selectively as they see fi But, in doing so, these HOAs are going directly against Section 70-1-522 of the Montana Code. Similar to the declarations in the Gwinnett County case, Lake Astorias Declarations provided that the HOA could not be held liable for any injury, damages or loss arising out of the manner or quality of approved construction on or modifications to any lot. Judge Dickenson ruled that this provision precluded Mrs. Ingmire from arguing that the HOA had a legal duty to enforce its architectural standards or design guidelines. The 1997 Amendment created the Windemere Homeowners Association, Inc., and made the Association responsible for necessary maintenance, repair, reconstruction, and snow removal on Windemere Drive. The email address cannot be subscribed. 34As the majority acknowledges, we stated in Higdem v. Whitham (1975), 167 Mont. Bibi v. Royal Hidden Cove at the Polo Club Homeowners Association, Inc. Appeals Court: 2008: Boyle v. Hernando Beach South Property Owners Association, Inc. Appeals Court: 2013: Carniello v. Second Horizons Condominium Association: Appeals Court: 2010: Carr v. Old Port Cove Property Owners Association, Inc. Appeals Court: 2009 HOA LAWS AND REGULATIONS. These rulings raise the question of whether HOAs can enforce neighborhood covenants selectively as they see fit. Stay up-to-date with how the law affects your life. There is no intermediate appellate court in the state. Most homeowners and condominium associations establish themselves as non-profit corporations. It has a constitutional mandate to oversee the operations of lower courts in the state. You're all set! 15The Appellants rely upon Lakeland Property Owners Association v. Larson (1984), 121 Ill.App.3d 805, 77 Ill.Dec. (b)that is required in order to comply with applicable federal, state, and local laws, ordinances, and regulations. Obviously, that is not the law of contracts, nor is it the law of covenants-as our own jurisprudence clearly reflects (Texas case law notwithstanding). While they are serving on the Supreme Court, they must continue to reside in Montana. We affirm. First Circuit Court of Appeals Weighs in on ADA Tester Standing Split, California Further Expands Leave Rights for Employees Caring for Loved Ones, ALL ABOARD: TSA ISSUES NEW SECURITY DIRECTIVE TO TRACKCYBERSECURITY EFFORTS BY THE RAIL INDUSTRY. Jonathan FRAME, Plaintiff and Appellee, v. . Objectively False: Eleventh Circuit Highlights Importance of Body Cameras, Policyholders obtain rare wins in COVID-19 coverage cases against insurers, Feds Consider Carving Out Exceptions to the Buy America Act, Modular Construction Components: Claim and Defense Considerations. 70-17-901. Blogs. For example, in both the Gwinnett County and Forsyth County cases described above, the homeowner did sue the neighbor who allegedly caused excess surface water runoff. The court stated that it was of no moment that the creation of the homeowners association may have exceeded the original purpose of the right to amend as contemplated by purchasers prior to the amendment. Lakeland, 77 Ill.Dec. The district court concluded that a sixty-foot-wide roadway easement (Elk Valley Road) existed that straddled the boundary of Plaintiffs' adjoining lots to the benefit of the other platted subdivision lots for ingress and egress to and from the subdivision and adjoining off-plat land. According to the HOA laws of Montana, associations may not prohibit homeowners from displaying political signs on their property or a common area in which the owner possesses an undivided interest. 24The District Court noted a maintenance provision in the 1984 covenants which provided in relevant part: Each property owner shall provide exterior maintenance. Each justice on the Supreme Court serves an eight-year term. The opinions published on Justia State Caselaw are sourced from individual, This site is protected by reCAPTCHA and the Google. Community associations have the freedom to create and enforce as many or as few regulations as they see fit as long as they do not contradict state or federal laws. It consists of 13 parts, listed below. Caughlin, 849 P.2d at 312. TermsPrivacyDisclaimerCookiesDo Not Sell My Information, Begin typing to search, use arrow keys to navigate, use enter to select, Stay up-to-date with FindLaw's newsletter for legal professionals. 6The Windemere Homeowners Association brought this declaratory judgment action seeking enforcement of a 1997 amendment to restrictive covenants on the Appellants' parcels of property near Big Flat Road in Missoula County. Copyright 2023, Thomson Reuters. :The Act governs the formation, management, powers, and operation of . %PDF-1.4 Therefore, they are bound by this Act. Newman, 277 Mont. Illinois Prejudgment Interest Struck Down What To Do Now, Massachusetts High Court Strikes Down Capital Gains Tax Levied Against Non-Domiciled Corporation on Statutory Grounds, Right result. T j:>TCHxLzehovOi![B}dNYPBH#{3{B}Ls5&sQnP,D7fz>6s9g)B]56CC=;\skoGz~2B}rsZ8cScRs yn;p|+&sRN8u Additionally, homeowners always have the option of getting involved on their HOA boards in order to push the enforcement of covenants. Housing discrimination victims can report any discriminatory acts to the U.S. Department of Housing and Urban Development or the Montana Human Rights Bureau. The court reasoned that these provisions permit land owners to take affirmative steps to provide a safe, clean condition, and that the 74 percent super-majority vote for the 1997 Amendment reflected the majority's opinion that the health and welfare of subdivision occupants were being compromised by increased road dust caused by ever increasing traffic on the non-paved road. Appellants declare that this statement is not supported in the record. This Court continues to follow the Schmid rule. Newman v. Wittmer (1996), 277 Mont. The Montana Human Rights Act consists of a Chapter specifically dedicated to Illegal Discrimination. The question before the court was whether it was proper to permit disparate impact claims under the FHA. About Supreme Court Find history, Justice biographies, cases, and more information about the Montana Supreme Court, the highest court of the Montana state court system. But, these condominiums must explicitly elect to follow the Act by recording a declaration in the county recorders office where the property is based. for the FREE & andrea e. maricich family trust, mickelson investments, llc, sallie a.losey, hemingway patrick & carol t. revocable living trust, plaintiffs and appellants, v. brown . Each acre shall be entitled to one (1) vote in any election to decide any issues involving waiver, abandonment, termination, modification, alteration or change of restrictive covenants as to a whole of the real property or any portion thereof. Therefore, anyone searching the public record can in fact identify which particular lots are bound by the 1997 Amendment. Additionally, the changes in the 1997 Amendment in this case do not constitute a prohibition on a use not previously restricted, as in Boyles. View the Court Calendar, Conference Agenda, and Upcoming Oral Arguments. About Supreme Court Find history, Justice biographies, cases, and more information about the Montana Supreme Court, the highest court of the Montana state court system. at 6, 917 P.2d at 929. 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