Blood v. Stoneridge at Fountain Green Homeowners Association, Inc.

Jonathan and Megan Blood (defendants) owned a home in a development overseen by the Stoneridge at Fountain Green Homeowners Association, Inc. (Stoneridge) (plaintiff). Stoneridge’s declaration of covenants, conditions, and restrictions (the declaration) required Stoneridge’s approval prior to altering property within the development. The declaration also prohibited solar panels on the front of houses, limiting them to the back. There were seven houses in Stoneridge’s development that had solar panels, none of which had panels installed on the front of the house. The Bloods began installing solar panels on both the front (15 panels) and back (33 panels) of their home without seeking Stoneridge’s approval. When installation was nearly completed, the Bloods sought Stoneridge’s approval. Stoneridge denied the Bloods’ application. Despite the denial, the Bloods did not take down the solar panels. Stoneridge wrote the Bloods a letter demanding that they take down the 15 panels on the front of the house, but they did not. Stoneridge brought suit, seeking a court order that the Bloods were in violation of the declaration and an injunction requiring the Bloods to remove the solar panels from the front of their house. The Bloods argued that the front-of-home restriction violated a state law that prohibited unreasonable limitations on the installation of solar panels. The statute stated that a limitation was unreasonable if it significantly increased the cost or decreased the efficiency of the solar panels. The circuit court granted Stoneridge’s request for declaratory and injunctive relief. The Bloods appealed.