Case brief summary
A California law says that written rules in a condominium's recorded property document must be enforced unless they are shown to be unreasonable.
Facts
A condominium owner kept three cats indoors in her unit, but the condominium association fined her because the complex's recorded rules banned cats and dogs.
Procedural history
The trial court dismissed her lawsuit, but a mid-level appeals court reversed, saying she could argue the rule was unreasonable as applied to her specific quiet, indoor cats.
Issue
Should a condominium pet ban recorded in the development's official governing document be judged by looking at the whole community, or by looking at one owner's individual situation?
Holding
The court held that such recorded rules must be presumed valid and judged by their effect on the whole development, not on one owner's particular facts.
Reasoning
The court reasoned that treating recorded rules as presumptively valid promotes stability, predictability, and fewer costly lawsuits, and the pet ban was rationally related to health, sanitation, and noise concerns in a large complex.
Opinions
Majority (Kennard): Recorded condominium use restrictions like pet bans are presumptively valid and enforceable unless arbitrary, against public policy, or far more burdensome than beneficial overall.
Concurrences (Authors): None, all other justices joined the majority opinion without writing separately.
Dissent (Arabian): The pet ban was unreasonable and arbitrary as applied because quiet indoor pets causing no harm provide real benefits with no offsetting burden to others.