Maronda Homes, Inc. v. Lakeview Reserve Homeowners Association, Inc.

Maronda Homes, Inc. (Maronda) (defendant) built a residential neighborhood in Florida and transferred control of the neighborhood to the Lakeview Reserve Homeowners Association (the association) (plaintiff). All homeowners who lived in the neighborhood were required to join the association, and the association was responsible for repairing common infrastructure in the neighborhood. After the association took control of the neighborhood, heavy rainfall flooded driveways and yards, eroded soil, and damaged roads throughout the neighborhood. An investigation revealed that there were structural issues with the drainage system and other aspects of the infrastructure throughout the neighborhood. The association filed a lawsuit in Florida state court against Maronda, alleging that Maronda had built a defective drainage system in breach of the implied warranty of habitability. Maronda moved for summary judgment, arguing that the implied warranty of habitability did not apply to infrastructure that was not attached to houses in the neighborhood. The trial court granted summary judgment for Maronda. The court of appeals reversed the trial court, holding that the implied warranty of habitability applied to the case because the contested infrastructure provided essential services throughout the neighborhood that affected the habitability of the homes in the neighborhood. Maronda appealed.