Bailey v. Stonecrest Condominium Association

Barbara Bailey (plaintiff) bought a Stonecrest condo to rent out, and after she told the association's board president that her tenant was African American, the president warned other residents might object; a resident then called Bailey using racial slurs and reporting objections to the tenant. Shortly after, the association proposed and residents approved by a two-thirds vote a bylaw restricting leasing (with a grandfather clause and hardship exception), and because Bailey's tenants moved out quickly and she did not seek the hardship exception, she was left unable to lease her unit. Bailey sued the association and board members (defendants), alleging the bylaw amendment was racially discriminatory and breached fiduciary duties; the association claimed the amendment had been proposed before Bailey's purchase, though meeting minutes did not support that. The trial court granted the association summary judgment, and Bailey appealed.