Long Meadow Homeowners' Ass'n v. Harland
89 So. 3d 573
Miss.2012Background
- Long Meadow subdivision outside Oxford; Phase I/II covenants restricted to one single-family dwelling per four acres; Phase III deeds initially allowed residential use, with some Phase III deeds permitting churches/schools.
- Harlands sought to build a church on Lots 2–4 in Phase III and obtained a deed in 2007 with covenants allowing church use; Leavells later executed a 2008 “corrected” warranty deed restricting to Phase I–II covenants and filed it without Harlands’ consent.
- Long Meadow Homeowners’ Association opposed the church and asserted equitable estoppel as a defense; Harlands sued to set aside the corrected deed and validate the original covenants.
- Chancery Court ruled for Harlands—validated original covenants and set aside the corrected deed; Court of Appeals affirmed; certiorari granted to address equitable-estoppel issue.
- Majority affirmance: court held Long Meadow Defendants failed to prove equitable estoppel; Harlands’ purchase records did not trigger estoppel against enforcing the covenants; no unconscionable reliance or change of position established.
- Dissent argues equitable estoppel should apply against Harlands due to Leavells’ representations relied upon by Phase III buyers, and would reverse and remand for consideration of reliance evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether equitable estoppel bars Harlands from building a church | Harlands relied on Leavells’ representations and land records | Defendants relied on lack of Phase III covenants; covenants not recorded for Phase III | Equitable estoppel does not apply; affirm |
Key Cases Cited
- PMZ Oil Co. v. Lucroy, 449 So.2d 201 (Miss. 1984) (applying equitable estoppel where representations induced purchase despite non-recorded covenants)
- White Cypress Lakes Development Corp. v. Hertz, 541 So.2d 1031 (Miss. 1989) (promised development use enforced across phases; estoppel against developer)
- Windham v. Latco of Miss., Inc., 972 So.2d 608 (Miss. 2008) (equitable estoppel restraints to prevent unconscionable results)
- First Investors Corp. v. Rayner, 738 So.2d 228 (Miss. 1999) (estoppel applied when deceit would unjustly enrich wrongdoer)
- B.C. Rogers Poultry, Inc. v. Wedgeworth, 911 So.2d 483 (Miss. 2005) (estoppel elements: belief, reliance, change of position, detriment)