Dalzell v. RP Steamboat Springs, LLC

Congress enacted the Interstate Land Sales Full Disclosure Act (“Land Sales Act”) to “prevent false and deceptive practices in the sale of unimproved tracts of *1219land by requiring developers to disclose [certain] information [to] potential buyers.” Flint Ridge Dev. Co. v. Scenic Rivers Ass’n of Okla., 426 U.S. 776, 778, 96 S.Ct. 2430, 49 L.Ed.2d 205 (1976). The plaintiffs before us, buyers of real estate in Routt County, Colorado, are precisely the type of buyers Congress sought to protect. They were lured into making large earnest money payments by the prospect of owning luxury condominium…