Why the Court Said ‘No’ to HOA Injunctive Relief

This case involved a dispute between a homeowners association (“Association”) and husband and wife property owners (“Owners”) over Owners’ failure to comply with Association’s governing documents relative to the condition of Owners’ property and their failure to pay fines imposed by Association.

Subsequent to Owners’ purchase of their property, their lot became the subject of numerous complaints from neighbors alleging excessive trash, debris, non-operational vehicles, and a dilapidated RV in violation of the community’s Covenants, Conditions, and Restrictions (CC&Rs). After issuing multiple notices and adopting a formal fine schedule, Association assessed escalating fines against Owners when they failed to remediate the issues or cooperate with property inspections. Owners refused entry to the property and denied any violation. Association filed suit to enforce the CC&Rs, recover unpaid fines, and seek injunctive relief.

The trial court found: (i) Association had adopted a proper fine schedule and followed the notice procedures set out in its CC&Rs; (ii) homeowners associations are not state actors and thus not subject to constitutional due process claims—however Association provided adequate notice and opportunity to cure under its governing documents; (iii) there was no credible evidence that Association had abandoned enforcement in the past or treated Owners unfairly; and (iv) Association had an adequate remedy at law through fines, assessments, and lien enforcement, making injunctive relief unnecessary. The trial court awarded judgment in favor of Association for: