Fountain Valley Chateau Blanc Homeowner's Ass'n v. Dep't of Veterans Affairs
Court of Appeal of California
79 Cal. Rptr. 248 (1998)
Cunningham (defendant) bought a home subject to Fountain Valley Chateau Blanc's (plaintiff) CC&Rs, which required maintaining interiors in a clean, sanitary, attractive condition while reserving owners' right to decorate as they pleased. Fountain Valley objected to the volume of papers, books, and belongings inside Cunningham's home, threatened litigation, and pushed him to remove items even after housing and fire inspectors found no hazardous conditions. When Fountain Valley sued after concluding Cunningham hadn't removed enough, Cunningham cross-complained for invasion of privacy, trespass, negligence, and breach of contract. A jury found Fountain Valley acted unreasonably, but the trial judge granted Fountain Valley a new trial, believing it had acted reasonably.
Whether a covenant requiring the interior of a home to be well-maintained can reasonably be construed to let a homeowners' association dictate the amount or placement of non-hazardous objects inside the home.