Chevy Chase Village v. Jaggers

In 1927, the Chevy Chase Land Company subdivided a piece of land it owned. The subdivision consisted of 13 blocks. Two blocks contained 60 lots and were set aside for commercial development. A few lots were designated for use by a church and a utility company. The approximately 200 remaining lots were exclusively for residential purposes. Each residential lot was bound by a series of restrictive covenants that appeared in each of the original deeds conveying the land. The covenants expressly stated they ran with the land and were binding on grantees and their heirs and assigns. Further, the restrictive covenants stated that the houses built on the lots were to be used for residential purposes exclusively. Finally, the covenants stated that any violation could be enjoined and enforced in a suit. In 1947, Dr. Frank Jaggers, Jr., and his wife (defendants) purchased a lot in the residential part of the subdivision. In 1954, Jaggers applied for and received a special exception from the county to use his property as a doctor’s office. Jaggers then used the property as both a residence and a doctor’s office. In 1967, Jaggers and his wife moved out and rented the residence part of the property. However, after moving, Jaggers still used the home as his medical office. Three other doctors lived in the subdivision and also used their homes as medical offices. At that time, the commercial lots were being used as a shopping center in the middle of the subdivision, in the manner originally intended. Chevy Chase Village, a landowner and municipal corporation (plaintiff), sued Jaggers and his wife in state court to enforce the restrictive covenant preventing Jaggers from using the home as his medical office. Following a hearing, the court denied the village injunctive relief, concluding that the restrictive covenant was not enforceable because the neighborhood's character had changed. The village appealed to the Maryland Court of Appeals.