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Mid-State Equipment Co., Inc. v. Bell

Supreme Court of Virginia
225 S.E.2d 877 (1976)


In 1945, James and Mary Eubank purchased 85 acres of land. They divided this land into several different plots. In doing so, they put conditions on these plots, one of which was that the plots were to be used for residential purposes only. In 1966, one of these plots was conveyed to James Hicks. In 1973, Hicks conveyed the land to Mid-State Equipment Co., Inc. (Mid-State) (defendant). The deed to Mid-State explicitly stated that the land would not be subject to the conditions placed by the Eubanks. Mid-State then began to use the property for its solid waste equipment business. Mid-State’s neighbors (Bell) (plaintiff) then brought an action for an injunction to prohibit Mid-State from using its land for commercial purposes.

Rule of Law


Holding and Reasoning (Compton, J.)

Dissent (Cochran, J.)

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