Franklin v. Spadafora
Supreme Judicial Court of Massachusetts
388 N.E.2d 1244 (1983)
The trustees of a condominium trust, represented by Spadafora (defendant), amended the trust's bylaws by an 80.45% vote to cap ownership at two units per person or entity; Franklin (plaintiff), who already owned six units, subsequently contracted to buy a seventh from Clark, but the trustees blocked the sale as violating the new bylaw. Franklin and Clark sued for a declaration invalidating the amendment and proceeded with the sale anyway; the trial court upheld the bylaw and voided the sale, and Franklin appealed.
Whether a covenant restricting the alienation of property is reasonable where the party imposing it does so to protect a property interest, the restraint is limited in duration, it serves a valid purpose, the prohibited conveyances are unlikely to be ones the restrained party would typically make, and the restriction affects only a small number of people.