McHuron v. Grand Teton Lodge Co.
1995 WL 380904, 1995 Wyo. LEXIS 107, 899 P.2d 38 (1995)
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Rule of Law:
An architectural review committee's decision to disapprove a homeowner's building plans based on a subjective aesthetic covenant is enforceable as a matter of law, provided the covenant establishes a general scheme of development and the committee's decision is reasonable. A decision is considered reasonable if it is consistent with the committee's historical application of the covenant and the existing character of the subdivision.
Facts:
- In May 1975, Gregory and Linda McHuron purchased a lot in the Jackson Hole Golf and Tennis Club Estates subdivision.
- Their deed was subject to a Declaration of Protective Covenants requiring written approval from the developer, Grand Teton Lodge Company, for all building plans and materials.
- The covenants specified that approval could be refused on the ground that the 'exterior is not in keeping with the surrounding landscape and natural beauty of the area.'
- Nearly 15 years after purchasing the lot, the McHurons submitted building plans for a home and requested permission to use fiberglass shingles for the roof.
- The Company's Architectural Review Committee denied the request for fiberglass shingles, informing the McHurons they should 'plan to use the standard cedar shakes used by all your neighbors.'
- Despite the Committee's disapproval, the McHurons proceeded to install the fiberglass shingles on their home.
Procedural Posture:
- Grand Teton Lodge Company filed a lawsuit against the McHurons in the district court (trial court), seeking a mandatory injunction to enforce the covenants.
- The Company filed a Motion for Summary Judgment.
- The district court granted summary judgment in favor of the Company, ordering the McHurons to remove their fiberglass shingles.
- The McHurons, as appellants, appealed the district court's order to the Wyoming Supreme Court, the state's highest court.
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Issue:
Does an architectural review committee act unreasonably when it disapproves the use of fiberglass shingles pursuant to a restrictive covenant requiring materials to be 'in keeping with the surrounding landscape and natural beauty,' where the committee has consistently and exclusively approved only wood shake and gravel roofs within the subdivision?
Opinions:
Majority - Thomas, Justice.
No. The committee's decision was not unreasonable. When a restrictive covenant establishes a general scheme for a development, an architectural committee acts reasonably when its decisions are consistent with the historical application of that scheme. The covenants unambiguously established a general plan to preserve the aesthetic character of the area, vesting discretion in the committee. Because all other homes in the subdivision had either wood shake or gravel roofs, the committee’s refusal to permit a new material (fiberglass shingles) was consistent with precedent and therefore reasonable. Courts should not substitute their own aesthetic judgments for those of a committee validly empowered by such covenants.
Dissenting - Golden, Chief Justice
Yes. The committee's decision may have been unreasonable, and the question should have been decided by a jury, not by a judge on summary judgment. While aesthetic covenants are generally valid, the question of whether a committee's refusal to approve plans is reasonable or arbitrary is a question of fact to be considered in light of the circumstances. The McHurons presented evidence raising a genuine dispute as to whether their proposed shingles were attractive, safe, and harmonious with the general plan, and they were denied due process by not being allowed to present this evidence at trial. A committee's aesthetic discretion is not unlimited and must be exercised objectively, not based on subjective whim, and a refusal should be based on proof of diminished value or harm to the general plan.
Analysis:
This decision strengthens the authority of architectural review committees by holding that consistency in enforcement is a key component of reasonableness. It establishes that a 'general scheme' can be defined not only by the text of the covenants but also by the observable, uniform character of the development that results from years of consistent enforcement. This precedent makes it more difficult for homeowners to challenge a committee's aesthetic decisions, shifting the legal inquiry away from the objective quality of a proposed material and toward the consistency of the committee's past actions. Consequently, homeowners challenging such a decision must now focus on proving the committee has been arbitrary or inconsistent in its application of the standards, rather than arguing about the merits of their specific design choice.
