Quimbee logo
DMCA.com Protection Status
From our private database of 18,800+ case briefs...

River Heights Ass'n v. Batten

Supreme Court of Virginia
591 S.E.2d 683 (2004)



Alice Batten (plaintiff) owned property in a subdivision along Route 29. The subdivision had four unimproved lots that were owned by Wendell Wood and his wife Marlene Wood (defendants). When the subdivision was created, the lots were under a restrictive covenant that prevented the lots from being used for commercial purposes. At the time the subdivision and the covenant were created, Route 29 was a two-lane road, and the area around the subdivision was comprised of residences and small businesses. At the time of trial, however, the area had become a highly developed commercial district, and Route 29 had been expanded to 10 lanes. There had been no change within the subdivision itself though. Wendell Wood sought to develop his lots into commercial properties. Wood argued that, due to the change in conditions around the subdivision, the doctrine of changed conditions applied, nullifying the restrictive-use covenant that prohibited commercial development. Batten sued, seeking enforcement of the covenant. The trial court ruled in favor of Batten. Wood appealed.

Rule of Law


Holding and Reasoning (Carrico, C.J.)

What to do next…

  1. Unlock this case brief with a free (no-commitment) trial membership of Quimbee.

    You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 498,000 law students since 2011. Some law schools—such as Yale, Vanderbilt, Berkeley, and the University of Illinois—even subscribe directly to Quimbee for all their law students. Read our student testimonials.

  2. Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.

    Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students. Read more about Quimbee.

Here's why 498,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 18,800 briefs, keyed to 985 casebooks. Top-notch customer support.
  • The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
  • Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
  • Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.

Questions & Answers

Have a question about this case?

Sign up for a free 7-day trial and ask it

Sign up for a FREE 7-day trial