Woodmoor Improvement Association, Inc. v. Brenner

The Brenners (defendants) petitioned the Woodmoor Improvement Association’s Architectural Control Committee (the committee) in 1990 to construct a new home with an adjacent satellite dish. The Woodmoor neighborhood had restrictive covenants that prohibited the homeowners from having “outside aerials or antennas.” Committee members interpreted the restriction differently from the Brenners, with some interpreting it to apply only to rooftop aerials or antennas and not satellite dishes, which were otherwise permitted, subject to additional covenant requirements for unsightly additions or structures to be screened from public view. The committee approved the Brenners’ plan, set specific requirements, and appointed a monitor to ensure compliance. The Brenners spent $30,000 to install their satellite dish and home-entertainment system. Committee decisions approving building plans were appealable to the Woodmoor Improvement Association (the association) (plaintiff), but none were filed by any party. Two years later, when the committee members who approved the Brenners’ satellite dish were replaced, the new board sought to enforce the covenant against the Brenners and requested that they remove their satellite dish. The Brenners refused, and the association sued for a permanent injunction prohibiting the Brenners from maintaining their satellite dish. The trial court found that although the Brenners’ dish was a prohibited aerial or antenna, the Brenners had reasonably relied on the committee’s decision—to their detriment—which equitably estopped the association from enforcing the covenant against the Brenners. The association appealed, arguing that the committee lacked the authority to allow the satellite dish and that even it did have the authority, then either the trial court erred in applying equitable estoppel to a clear violation of the covenants or the Brenners did not satisfy the reliance element of the estoppel doctrine.