Manchester Oaks Homeowners Ass'n v. Batt
284 Va. 409
| Va. | 2012Background
- Manchester Oaks HOA governs 57 townhouses (30 Garaged, 27 Ungaraged) with 72 parking spaces in a common area.
- Declaration (1989) grants HOA authority to designate parking via Section 2.3.18 and to set rules for the Common Area; Section 3.1 preserves equal enjoyment rights subject to HOA rules.
- From 1993–1994 the developer marked some spaces as “reserved” for Ungaraged Lots and kept 18 as “visitor” spaces; 2009 policy restricted visitor parking to one permit per owner.
- Amendment (Dec. 2009) created Reserved Common Area and empowered non-uniform, preferential parking assignments for Ungaraged Lots; later added Section 3.1.10 authorizing non-uniform licenses.
- Plaintiffs (Batt, Grom, Martin) allege unequal parking assignments violate the Declaration; seek damages, costs, and attorneys’ fees under Code § 55-515(A); circuit court held Amendment invalid and awarded damages and fees.
- On appeal, the Virginia Supreme Court affirms in part, reverses in part, and remands for further cost/fee determinations.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether parking must be allocated equally among all lots. | Batt/Grom contend equal allocation is required by the Declaration. | HOA argues no express equal-allocation obligation; allowed to allocate variably. | Equal allocation required; Sully Station controls; affirmation of that aspect. |
| Validity of the December 2009 Amendment. | Amendment improperly adopted; seeks invalidation. | Amendment proper under Declaration; no basis to void. | Amendment invalid due to improper adoption/notice; independent basis supports ruling. |
| Measure and recoverability of damages for loss of value and related costs. | Damages from loss of parking space and related assessments; value diminution proved. | No proven diminution in value; damages speculative. | Damages for diminution of value reversed; maintenance-assessment damages upheld; certain tax damages reversed. |
| Whether plaintiffs are entitled to costs and attorneys’ fees under Code § 55-515(A). | White v. Boundary allows prevailing homeowners to recover. | HOA argues statute limits recovery to certain prevailing-party scenarios. | Statute authorizes costs/fees for claims enforced by Declaration; only breach-of-contract portion recoverable; amount affirmed. |
Key Cases Cited
- Sully Station II Community Ass’n, Inc. v. Dye, 259 Va. 282 (2000) (common area rights require equal access absent express contrary provision)
- White v. Boundary Ass’n, Inc., 271 Va. 50 (2006) (owners may recover costs and fees when enforcing a declaration)
- Ulloa v. QSP, Inc., 271 Va. 72 (2006) (attorney-fee awards depend on prevailing claims and statutory basis)
- Campbell County v. Royal, 283 Va. 4 (2012) (correct measure of damages is diminution in value, not replacement value)
- Rappold v. Indiana Lumbermens Mut. Ins. Co., 246 Va. 10 (1993) (abuse of discretion standard for evidentiary rulings and discovery issues)