Appeals Court Clarifies Permit Expiration Extensions

Nathaniel Stevens, Esq.

Perhaps surprisingly, only after the fourth time Massachusetts enacted legislation extending the life of most land use and

environmental permits, there is now an appellate-level court decision ruling that such extensions are added onto, rather than run concurrently with, the time period set by the law under which the permit was granted.  

In May, the Appeals Court ruled that two building permits granted for construction of a biomass-fired power plant in Springfield, MA benefited from extensions granted by the several permit extension laws and did not forego the additional time due to lengthy litigation challenging their validity. The case is Palmer Renewable Energy, LLC v. Zoning Board of Appeals of Springfield. 

Massachusetts law has long recognized the doctrine of litigation tolling for land use permits.  Under this doctrine, courts have applied equitable tolling when a permit has been challenged to avoid the futile situation of a permit holder not being able to exercise their rights under a permit if the litigation takes longer than or eats up any portion of the term of a permit. 

Certain statutes, such as the Zoning Act, codify equitable tolling to explicitly provide for tolling of the expiration date of a permit until litigation concludes. 

Regardless of whether a permit is challenged in court, for other reasons the Legislature in recent times has granted blanket extensions to a broad range of land use and environmental permits.  In 2010, legislation known as the Permit Extension Act, was enacted and then amended in 2012, resulting in permits in effect during the “qualifying period” between August 15, 2008, and August 15, 2012, being extended four years.  The Permit Extension Act was in response to the downturn in the state’s economy during the Great Recession around 2008. 

In response to the COVID-19 health emergency, the Legislature in 2020 enacted provisions tolling many of the same land use and environmental permits until the end of the Governor’s State of Emergency due to the pandemic. That State of Emergency lasted 462 days so permits that were in effect on March 10, 2020 were extended 462 days.   

Most recently, as part of an omnibus economic development bill, known as the Mass Leads Act, the Legislature included a provision to extend by two years many of the same type of land use permits if they were in effect at all during the period of January 1, 2023, to January 1, 2025.

The Appeals Court in the Palmer case was asked to resolve the question of whether the extra four years provided by the Permit Extension Act ran from the date two building permits were issued while the permits were challenged in court, or whether the four years began the date the litigation concluded.  The decision holds that they run not concurrently but rather consecutively. 

The Springfield building commissioner on November 15, 2011, issued two building permits to Palmer to begin construction of a biomass-fired power plant. While no expiration date was stated on the face of the permits, the parties and courts treated the permits as having a 180-day term.  Within a month of the permits being issued, the Springfield City Council appealed to the Zoning Board of Appeals (“ZBA”). The ZBA voted on January 12, 2012, to revoke the building permits and filed its decision with the City Clerk on March 8, 2012.  

Palmer appealed the ZBA’s decision by filing a complaint in the Land Court on March 26, 2012.  The Land Court on August 14, 2014, reversed the ZBA’s decision and reinstated the building permits.  The City and others appealed and, over a year later, on September 8, 2015, the Appeals Court affirmed the Land Court’s decision.  An application for further appeal was denied. 

Five years later, on October 14, 2020, twelve members of the City Council asked the building commissioner to issue a cease-and-desist order on Palmer’s construction on the grounds that the building permits had expired.  The request was denied and the City Council members appealed to the ZBA. On May 5, 2021, the ZBA voted to grant the relief and revoked the building permits and filed its decision 23 days later with the City Clerk.  Palmer appealed the ZBA’s decision in Land Court. 

In affirming the ZBA’s decision, the Land Court held that the extra time provided by the Permit Extension Act ran at the same time as that provided by the litigation tolling doctrine, concluding that the permits had expired May 13, 2016. 

In reversing the Land Court, the Appeals Court began its analysis recounting the several ways land use permits are extended by the doctrine of equitable tolling, automatic through statutory provisions, or following statutory or local procedures to request an extension.  

The Appeals Court then relied on the principle that when enacting a law, the Legislature is presumed to be aware of existing statutory and common law related to the subject it is legislating, so by starting extension provisions in the Permit Extension Act with the clause, “Notwithstanding any general or special law to the contrary”, the phrase “in addition to the lawful term of the approval” means that the four-year extension provided runs after, not concurrently with, any period provided by litigation tolling. 

The Appeals Court also was asked to decide what date is used to start the litigation tolling period.  Palmer asserted that it was when the City filed its appeal to the ZBA, 27 days after the building permits were issued.  The City maintained it was when the ZBA reached its decision and revoked them. Because of the dates involved, this was significant because depending on which date was used, the building permits could fall under the COVID-19 permit extension law and enjoy another extension.  

The Appeals Court decided that, in the context of this case where the City challenged a large and complex project by asserting it also needed a special permit, it sided with Palmer’s position. Adding the 153 days remaining on the building permits to the date when litigation finally ended on October 30, 2015, meant that the building permits expired March 31, 2016.  The Permit Extension Act extended these permits four years through March 31, 2020, thus affording the further extension under the COVID-19 permit extension law. 

While the facts and time periods in the Palmer case are complex and perhaps unique, the ruling is favorable to those holding state, regional or local land use and environmental permits. Equally, the decision should be noted by those administering or enforcing such permits as this case gives the permits longer life than may be expected.   

When using the words “notwithstanding any general or special law to the contrary” in special legislation extending such permits “in addition to the lawful term of the approval”, the additional time will be added to any other additional time afforded.  It does not run concurrently but rather consecutively with any other time periods granted under statutory provisions, litigation tolling, or granted extensions.   

Permit holders and their legal counsel should know about and keep copies of ALL four of the Massachusetts permit extension laws, the Zoning Act and other sources of statutory extensions, and the Palmer case applying the equitable tolling doctrine.

A member of REBA’s Environmental Law Section and a partner of McGregor Legere & Stevens PC, Nathaniel Stevens handles a broad range of environmental and land use matters, from administrative law to litigation. He has helped a diversity of clients with environmental issues including permitting, permit appeals, development, contamination, transactions, conservation, real estate restrictions, water supply, water pollution, subdivision control, tidelands licensing, Boston and state zoning, coastal and inland wetlands, stormwater, air pollution, and energy facility siting.  Nathaniel’s email address is NStevens@mcgregorlaw.com.

Condominium Board Problems and Questions: Asked and Answered

 Mark S. Einhorn

The Problem: Our condo board does not always meet the quorum required to make decisions at board meetings.

The Answer:  Your board definitely should not make major decisions – increasing common area fees or approving a major renovation project, for

example – without a quorum.  However, you can deal with emergencies and make the day-to-day decisions required to operate the community outside of an official meeting.  When that is necessary, it is a good practice to ratify the decision at a future meeting when the quorum requirement is met. 

Some association bylaws specify that boards can act without a quorum in an emergency.  If your bylaws don’t contain that provision, the board might consider asking owners to approve an amendment including it, eliminating any question about whether an emergency decision was authorized.

If the lack of a quorum is a chronic problem rather than an occasional one, the board should try to identify any issues that are creating attendance obstacles.  Perhaps there are different days or times that would be more convenient for chronically absent board members. 

If the problem isn’t the timing of the board meetings but the behavior of the board members, the other trustees should confront them. Regular attendance should be a requirement for board members.  Those who can’t or won’t fulfill their obligations should be encouraged to resign. If they refuse, the board should consider using the formal process outlined in the association’s bylaws to remove them. 

Even if the board has a quorum, the absence of one or more members can result in tie votes that leave the board deadlocked on important issues.  Some boards deal with this problem formally, by adopting an arbitration or mediation requirement; others resolve tie votes less formally, by drawing straws or rolling dice.  The best strategy is for board members to craft a compromise resolving their impasse.  Although compromise seems to have gone out of fashion in recent times, it remains a desirable solution, if not always an easily achievable one.

The Problem:  A member of our board is not a team player – to say the least.  He regularly bad mouths decisions with which he disagrees, encourages owners to complain about the decisions and even to remove the trustees who supported them.  One board member thinks we should vote to remove him. Is that an option?

The Answer: No.  If this “rogue” trustee is an officer, a majority of the trustees could vote to remove him from that position.  But you can’t typically vote to remove him from the board unless the condominium documents give the board that authority.  Most association documents outline a formal removal process requiring a vote of the owners that you would have to follow.  And while that is an option, it is not the first one you should consider. 

Start instead by explaining the “duty of loyalty” trustees owe the board and the community.  That duty requires trustees to accept board decisions as final and to support publicly even the decisions they have opposed.  If this board member can’t accept that fundamental principle of association governance, he should resign.  If the board president or other trustees have already delivered that message, then it should come next from the board’s attorney in a sternly worded letter that also explains the removal option and the board’s willingness to pursue it. Sometimes the threat of removal is enough to persuade a rogue to change his behavior or resign.

Removal is a last resort, however, and an undesirable one, because it will require embroiling owners in a public and potentially divisive battle. Even if the trustee is ultimately recalled, the bitter feelings will no doubt linger.

If the board member’s term is ending, it would be better to wait for the annual election (assuming the wait is not too long) and either try to persuade him not to run for re-election or try to persuade owners to elect someone else.

But before initiating a vote to recall the trustee or campaigning against him, the board should consider what is motivating his behavior. Does he have a personal axe to grind; is he just seeking attention? Or does he have a good reason for questioning the board’s decisions?  You should consider the board’s behavior as well as his.  What if this rogue is right and the rest of the board is wrong?  It’s not likely, but it is a question you should ask and a possibility you should consider.

A partner in the Braintree firm of Marcus Errico Emmer & Brooks P.C., Mark concentrates his practice on transactional and condominium law.  He advises condominium associations and association managers on all matters affecting condominium communities, including:  governance issues, rules enforcement, lien enforcement, asset management, casualty loss claims, document amendments, land acquisition and development rights, election and transition procedures, contracts and general liability issues.  Mark can 

Hoarding Is a Disability: Boards Must Treat it Like One

 Matthew W. Gaines

“This is a disgusting mess?” How many parents have said that about a teenager’s room?  The number who have not said it would no doubt be considerably smaller – probably

close to zero. But in this case, the comment was coming from a condominium manager, who was describing the living room of an owner she thought was a “hoarder.”    A parent can tell a teen, “Clean your room or else.”  Dealing with an owner (“my home, my castle”) is obviously more complicated; dealing with a hoarder is several orders of magnitude more complicated still.

The key question is whether the mess the manager sees is the result of poor housekeeping or hoarding.  It is a distinction with a critical difference, determining whether and to what extent the association’s board can or should intervene.  The fault line will be whether the condition of the unit poses a threat to common areas, other units or the health and safety of residents.

The Nature of the Threat

There are two types of hoarding:  A -- the most worrying type; and B – also worrying but less problematic than A.

Supreme Court Justice Potter Stewart once said, famously, that he couldn’t define pornography, “but I know it when I see it.” Distinguishing between these two types of hoarding is easier.  Weeks of unwashed dishes stacked on counters and piled in the sink, garbage spilling out of containers and onto the floors, papers stacked on top of the stove (or stored in the oven), dozens of stray cats living in the unit without benefit of litter boxes, the sight of pests or clear evidence of their presence, mold and mildew growing on the bathroom wall  -- these conditions pose a threat to others because of the fires they can cause, the odors and other unsanitary conditions and health hazards they can produce.

Excessive clutter -- magazines, clothes and assorted objects covering the floors, boxes stacked waist high -- pose a threat to the occupant, because emergency responders might have trouble reaching him if he suffers a medical emergency.  But the impact on other condominium units or other residents isn’t immediate and so is less of a concern to managers and boards. 

Both types of hoarding require a response, but the responses should be different.  With Type B, the goal is to prevent a potential threat from becoming an immediate one.  Because the threat isn’t imminent, the response can be gentler and the timeline for dealing with it longer.  Type A requires a more urgent response, because the threat already exists and the timeline for correcting the problem must be shorter. 

Whether you are dealing with a Type A or Type B hoarder, you are dealing with someone who has a disability.  You have to treat owners suffering from it sensitively and with respect. You shouldn’t immediately start serving violation notices and imposing fines, because those aggressive actions aren’t likely to be effective and equally important, because hoarding qualifies as a disability.  Imposing a fine - a form of punishment - could be deemed illegal discrimination under both the state and federal Fair Housing Acts.  

 

How to Respond

At the same time, you have to consider the impact on other residents.  You can’t punish the hoarder, but you have to protect the community.  So the board has an obligation to deal with the problem.  What should you do?

1.    Start by verifying that you are dealing with a hoarding situation.  Assess as best you can the extent of the problem. Is it Hoarding A, requiring immediate action, or Hoarding B, permitting a less urgent response?

2. Contact the association’s attorney.  Because hoarding is a disability, there are Fair Housing Act implications, creating the potential for a discrimination claim and liability risks for the association.  Legal advice will be essential.

3.   Start with the least intrusive, least costly, and least heavy-handed measures and work up from there.  Try talking to the owner first. If he or she isn’t responsive, try to get family members involved.  Often, relatives either aren’t available or aren’t interested, but sometimes they are unaware of the problem and will step up if informed.

4.  Contact local social services agencies: Elder Affairs if the resident is a senior, Veterans Affairs if you’re dealing with a veteran, can be helpful.

5.  Get a hoarding expert involved.  Some counties have created hoarding task forces with professionals who may be able to work directly with hoarders and/or advise boards on how to deal with them. 

6.   Contact local health and safety officials – the Department of Health, the Fire Department or the Building Department.  If the clutter violates health and/or safety codes, these agencies may issue a citation ordering a clean-up.   The obvious advantage: Local officials rather than the board would be the ‘bad guys,’ enforcing the cleanup order. 

7.    Go to court.  Litigation is never the first choice, but it may be necessary if you can’t persuade the owner to address the problem voluntarily. Although the courts are often reluctant to intervene and tend to move slowly if they do, you may be able to get a preliminary injunction requiring an immediate response by the hoarder, if you can show that the conditions in the unit pose a threat of immediate and irreparable harm to others.  Take pictures if you can; they will provide the best evidence documenting your concerns.  Affidavits from the manager, board members or residents who have seen the conditions first-hand can also be persuasive. 

8.     Require ongoing monitoring.  The goal is to get the unit cleaned, but hoarding is a disease and eliminating the clutter won’t cure it.  That’s why you want a court-ordered clean-up to include an inspection requirement.  If no one is watching, the hoarding problem you think you have solved may recur.  The advantage of obtaining a court order: If the owner violates it by failing to clean the unit or by failing to keep it clean, you can ask the court to enforce the existing order.  You don’t have to seek a new one.  

Dealing with a hoarding situation requires diplomacy, patience and sensitivity both to the owner who is suffering from a disability and to the other residents who are affected by the owner’s behavior.  Strategies that balance those competing interests have the best chance of producing a long-term solution that works for everyone.

Co-chair of REBA’s Legislation Section, Matt Gaines Matt is a partner in Marcus Errico Emmer & Brooks, P.C., concentrating his practice on commercial and residential real estate acquisitions, as well as condominium and community association law.  Matt can be contacted at mgaines@meeb.com.

Mandatory Compliance with Massachusetts Large Building Energy Reporting (LBER): Requirements for Condominium Associations

Troy Tanzer

Is Your Condominium on the List? Important LBER Reporting Obligations for 2025

The Massachusetts Department of Energy Resources (DOER or Department)

has implemented new energy reporting requirements that directly impact condominium associations across the Commonwealth. If a building is 20,000 square feet or more, the Large Building Energy Reporting (LBER) law applies.

What Buildings Are Covered by LBER?

LBER was established by An Act Driving Clean Energy and Offshore Wind (Chapter 179 of the Acts of 2022, § 41), codified as M.G.L. c. 25A, § 20. The law applies to any building, including condominiums, with a Gross Floor Area of 20,000 square feet or more, located on one or more parcels.

Under LBER, “Distribution Companies” of utilities (electric, gas, steam) are required to report a building’s energy usage annually. However, building owners or their agents are responsible for submitting usage data for other energy sources like oil, propane, wood, and on-site renewable energy systems.

The DOER has released the final Covered Buildings List identifying all properties with reporting obligations due by June 30, 2025.

What Are the Reporting Requirements?

LBER imposes annual reporting duties on several parties:

1.    Distribution Companies- Annually by May 30^th, each Distribution Company shall report to the Department all Energy Usage provided by the Distribution Company for all Covered Buildings for the previous calendar year. Such Energy Usage shall be reported at the meter level for each Covered Building unless an exception is approved pursuant to 225 CMR 27.04(1)(c). Such Energy Usage shall be provided for each Covered Building and shall be submitted in a manner established by the Department in its Distribution Company Reporting Guideline.

2.    Municipal Utilities- Annually by May 30^th, each Municipal Utility shall report to the Department all Energy Usage provided by the Municipal Utilities for all Covered Buildings for the previous calendar year. Such Energy Usage shall be reported at the meter level for each Covered Building unless an exception is approved pursuant to 225 CMR 27.04(2)(b). Such Energy Usage shall be provided for each Covered Building and shall be submitted in a manner established by the Department in its Municipal Utility Reporting Guideline. A Municipal Utility may request to submit Energy Usage aggregated to the Building level for a Covered Building or group of Covered Buildings. Such a request shall detail why the submission of meter level data for the Covered Buildings is not possible or practicable. The Department shall review such requests on a case-by-case basis

3.    Building Owners (Including Condominium Associations)- Annually by June 30^th, building owners shall provide all Energy Usage that is not provided by a Distribution Company or Municipal Utility for all Covered Buildings where they are listed on the Covered Buildings List as the building owner. Energy Usage shall be reported using Energy Star Portfolio Manager or any other Department-approved program in a manner to be specified by the Department in its Building Owner Reporting Guideline.

1.    Building Owner- The person, persons, entity, or entities listed in the Covered Buildings List as the owner or designated building owner of a Covered Building.

2.    Designated Building Owner- A person or entity that has been designated by the building owner pursuant to 225 CMR 27.06(2)-(3) as responsible for compliance with 225 CMR 27.00

4.    Campus Designations- building owners that have received approval to designate a collection of Buildings as a Campus pursuant to 225 CMR 27.03(5) shall report Energy Usage for all Buildings on that Campus pursuant to the plan approved by the Department under 225 CMR 27.03(5).

Alternative Compliance Options

If your building cannot comply by June 30^th, you may request a deadline extension or modification of reporting requirements (requests are reviewed on a case-by-case basis).

If you already report under Boston’s Building Emissions Reduction and Disclosure Ordinance (BERDO), or Cambridge’s Building Energy Use Disclosure Ordinance (BEUDO), then no additional reporting is required under LBER. Your municipal reports will satisfy LBER’s requirements.

How to File/Comply

All building owners must file through the Massachusetts BEAM Portal, which provides tools for:

• Uploading building lists
• Entering and validating energy data

Visit the DOER’s Building Owner Guidance page for step-by-step instructions. Additional resources will be made available, including one-page sheets and tutorials.

What If You’re Not Sure Your Condominium Is Covered?

In February 2025, the DOER mailed notification letters to building owners listed on the Covered Buildings List. If you’re unsure:

• Search the list on DOER’s website or through the BEAM Portal.
• If your condominium is under 20,000 sq. ft. and appears on the list in error, you may submit a Dispute Inclusion Form by April 30, 2025.
• You may also apply for an exemption if the building was:
• Vacant for a full calendar year
• Demolished in the previous calendar year
• Vacant more than 50 percent of the year due to natural causes (fire, flood, damage, etc.)
• Filed or been dissolved in bankruptcy
• Affected by other unique, documented circumstances

What Happens If You Don’t Comply?

Failure to report by June 30^th may result in:

1.    A written notice from the DOER.

2.    A daily fine of up to $150, beginning 30 days after notification.

A building owner may not pass through a fine assessed pursuant to 225 CMR 27.11(3)(a)2. to a lessee of a unit within a Covered Building that comprises less than five percent of the total Gross Floor Area of the Building. If a lessee that comprises greater than five percent of the total gross floor area of a Covered Building fails to respond within 30 days to a written request for Energy Usage information submitted by a building owner pursuant to 225 CMR 27.04(3)(a), the Department may take the following enforcement actions:

1.    A written notice from the DOER.

2.    A daily fine up to $150, beginning 30 days after notification.

Key LBER Timeline

• March 30, 2025 – Final Covered Buildings List published
• April 30, 2025 – Deadline to dispute inclusion in the List. Building owners can enter a dispute within the BEAM Portal.
• June 30, 2025 – Reporting deadline for all utilities and building owners.
• October 31, 2025 – Public release of building energy data and greenhouse gas emissions reports.

The October release will include a searchable online database and map, showing each Covered Building’s reported energy use and emissions profile.

Your Next Steps

1.    Check the Covered Buildings List and confirm if your condominium is listed.

2.    If listed, begin gathering non-utility energy data and register with BEAM.

3.    Submit your report by June 30, 2025.

An associate in the Boston and Quincy-based firm of Moriarty Troyer & Malloy LLC, Troy handles a variety of real estate matters with an emphasis on zoning and land use.  Troy can be contacted at ttanzer@mbmllc.com 

  

Environmental Justice and the Legal Profession (Video)

10 Things to Know About the Hampden County Registry of Deeds

1. We have TWO (2) FULL-SERVICE OFFICES (Record in Both Recorded and Registered Land and Record Plans):

 

• Springfield – 436 Dwight Street, B42, Springfield, MA 01103 

• Westfield – 59 Court Street, Rm#104, Westfield, MA 01085

 

2. We have Historical Documents (images) going back to 1636.

 

3.    We have Indexed Documents going back to 1947.

 

4. E-Recording is available for BOTH Recorded and Registered Land.

 

5. You can E-Record Multifunctional Documents in our Recorded and Registered Land departments up to 10 notations (check with your E-Recording company for participation and availability and check with our Office for filing fee determination).

 

6.    We offer FREE Public Notary service for anyone who wishes to record a Declaration of Homestead form with our Office.

 

7.1Emailing complicated documents in advance for our review is HIGHLY recommended and encouraged to avoid unnecessary rejections and delays.

 

8.   We have a FREE FRAUD ALERT SERVICE, the Consumer Notification System – sign up and be alerted immediately should any document that includes your name be recorded at our Registry.

 

9.    Our Registry offers FREE workshops (Registry on the Go!) to any of the 23 Cities and Towns within Hampden County where we discuss the following topics:

 

• What we do and where we are located

• Declaration of Homestead 

• Consumer Notification System – Free Fraud Alert

• Free Certified Copy of Deed and Declaration of Homestead to any Hampden County resident

Just contact us to schedule a workshop in your City and Town!

 

10.  We are constantly working with the newest technology to improve our images and records.  We are currently partnering with Boston University to create a transcription program to digitize our historical records. The goal is to transcribe the Old English Script which was used in the early 17^th Century to digitized print…Stay Tuned!!! 

Massachusetts High Court Clarifies Zoning Rules for Sober Homes: What Property Owners and Municipalities Need to Know

Stephanie T. Reed

In a decision with statewide impact, the SJC recently clarified how zoning laws apply to sober homes. In Bak Realty, LLC v. City of Fitchburg, the Court ruled that a sober home may not be excluded from a residential

neighborhood if the residents are functionally the equivalent of a family. This standard focuses not on blood or marriage ties, but on whether the individuals live together in a stable, cohesive household. This means sharing meals, responsibilities, routines, and exhibiting a commitment to communal living, much like a traditional family.

The case arose after the City of Fitchburg tried to block a sober home from operating in a single-family residential zone. The SJC held that Fitchburg could not use its zoning code to exclude housing for people in recovery when the residents function like a family and are protected under federal anti-discrimination laws such as the Fair Housing Act and the Americans with Disabilities Act.

This ruling has important implications for both property owners and local governments. For owners and operators of sober homes, it offers support, but also a reminder that the household must be genuinely cooperative and not just a group of individuals living under the same roof. For cities and towns, it signals the need to revisit zoning definitions that narrowly define “family” in ways that may violate federal law.

Communities across Massachusetts have grappled with similar issues, sometimes facing lawsuits or HUD complaints. In Worcester, for instance, the city has been involved in litigation with sober house operators that raises the question whether lodging house requirements discriminate against individuals with disabilities. Similarly, in New Bedford, the city has taken steps to regulate sober homes and lodging houses, prompting discussions about the balance between local control and federal anti-discrimination laws. The Bak Realty ruling provides clearer guidance, but also raises new questions about how municipalities can regulate group housing without crossing legal lines.

Legal guidance is especially important in areas like this, where zoning codes, disability rights, and federal protections intersect. Whether you’re a property owner planning a new use, or a municipality trying to enforce local ordinances, it’s best to get ahead of issues before they turn into a dispute.

Stephanie is an associate in the litigation practice group, at Prince Lobel Tye LLP. In her practice, Stephanie defends companies and individuals in high stakes matters, including commercial and business litigation, construction, intellectual property, insurance defense, media and privacy law, and other areas of complex civil litigation.  Stephanie can be contacted at sreed@princelobel.com.

Have questions about zoning and sober homes in your community? Contact Ann Sobolewski or any member of Prince Lobel’s Real Estate group to learn how this decision may affect your rights and responsibilities.