Long Green Valley Ass'n v. Bellevale Farms, Inc.

Summary

The Maryland Court of Appeals held that an agricultural preservation easement purchased by the Maryland Agricultural Land Preservation Foundation did not constitute a charitable trust. Accordingly, the Long Green Valley Association and adjacent landowners were not “interested persons” entitled to enforce the easement under Maryland Estates and Trusts Article § 14-302(a). The court affirmed the judgment that petitioners lacked standing to challenge construction and operation of a creamery on the preserved farmland.

Holdings

1. Res judicata and collateral estoppel did not bar or moot the appeal because the prior zoning case involved different causes of action and legally determinative issues; it concerned the validity of a zoning special exception, not whether the agricultural easement was a charitable trust.
2. The Bellevale Easement did not create a charitable trust because the deed did not manifest an intent to create one and did not impose duties to hold or administer property for a charitable purpose.
3. Petitioners lacked standing under § 14-302(a) because the Bellevale Easement was not a charitable trust and petitioners were not interested persons entitled to enforce such a trust.

Questions Presented

1. Whether the related zoning appeal in Long Green Valley Ass'n v. Prigel Family Creamery barred or mooted the present appeal under res judicata or collateral estoppel.
2. Whether an agricultural preservation easement purchased by the Maryland Agricultural Land Preservation Foundation creates a charitable trust under Maryland law.
3. Whether petitioners qualify as interested persons under Maryland Estates and Trusts Article § 14-302(a) and therefore have standing to enforce the easement.

Disposition

affirmed