Garden Lakes Community Association, Inc. v. Madigan

204 Ariz. 238 (2003)

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Garden Lakes Community Association, Inc. v. Madigan

Arizona Court of Appeals
204 Ariz. 238 (2003)

Facts

The Garden Lakes Community Association, Inc. (the association) (plaintiff) was the homeowners’ association for a subdivision in Avondale, Arizona. The association adopted covenants governing land use in the subdivision. The covenants provided that no work could be performed on a home’s exterior without approval from the architectural-review committee (ARC). The association also established architectural-review guidelines (the guidelines), which provided, among other things, that (1) solar-energy devices that would be visible to the public or neighboring properties had to be approved by the ARC before installation, and (2) solar panels and equipment had to be integrated into the home’s design. William and Joan Madigan (defendants) and Henry and LaVonne Speak (defendants) purchased lots in the subdivision and accepted the deeds to their properties subject to the covenants and guidelines. However, the Madigans and the Speaks subsequently installed solar-energy devices (SEDs) on their homes’ roofs without obtaining approval from the ARC or the association. The association sued the Madigans and the Speaks, alleging failure to comply with the covenants and the guidelines. The association sought permanent injunctive relief that would have required removing the SEDs. The Madigans and Speaks asserted that the association’s guidelines were void and unenforceable under Arizona Revised Statute § 33-439(A). That statute provided that any covenant, restriction, or condition in a deed that “effectively prohibits” the installation or use of SEDs was void and unenforceable. William Madigan died before trial, and Joan Madigan removed the SEDs from her home. At trial, the association presented expert testimony suggesting that there were feasible alternative designs for the Speaks’ SEDs that would have complied with the guidelines, including constructing a patio cover to hold the solar panels or building an aesthetic screen. However, the Speaks presented testimony demonstrating that those alternatives were unfeasible, unworkable, costly, and likely to decrease solar efficiency. The trial court ultimately entered judgment in the Madigans’s and the Speaks’s favor, concluding that the association’s guidelines had effectively prohibited the Speaks from putting SEDs on the home. The association appealed.

Rule of Law

Issue

Holding and Reasoning (Gemmill, J.)

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