Prince George’s County v. Greenbelt Homes, Inc.
Maryland Court of Special Appeals
431 A.2d 745 (1981)
John Hemphill and Lynn Bradley jointly contracted to purchase a unit from a cooperative housing unit run by Greenbelt Homes, Inc. (defendant) in Prince George’s County, Maryland. The contract was subject to a provision requiring Greenbelt Homes, Inc., to accept Hemphill and Bradley as members. However, Greenbelt Homes, Inc., denied Hemphill and Bradley a membership on the ground that they were not married. Hemphill and Bradley filed a complaint to the Human Relations Commission of Prince George’s County, which reviewed the contract. The contract contained a covenant that members of Greenbelt Homes’ cooperative housing unit were to occupy the unit with “himself and his immediate family.” The commission rejected the generally accepted interpretation of family offered by Greenbelt Homes. The commission took notice of the dictionary definition of family as including “a group of individuals living under one roof.” The commission also reviewed local ordinances, holding that up to five unrelated individuals could live together in a single household unit. The commission concluded the covenant, as interpreted to limit membership to married couples, was invalid under a local ordinance against discrimination of an individual based on marital status. Prince George’s County (plaintiff) filed a suit for declaratory judgment and mandatory injunction in circuit court to enforce the order of the commission. Both parties submitted motions for summary judgment. The trial court granted Greenbelt Homes’ motion, holding that the ordinance did not prevent Greenbelt Homes from limiting its memberships to married couples. Prince George’s County appealed.
Rule of Law
Holding and Reasoning (Lowe, J.)
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