This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
A nonprofit organization leased a residence in a planned subdivision to operate a group home for four individuals with AIDS, providing them with a family-like environment and in-home nursing care. Neighbors objected, citing increased traffic and alleging the group home violated a restrictive covenant limiting properties to "single-family residence purposes" (paras 2-4).
Procedural History
- District Court, August 12, 1993: The court ruled in favor of the neighbors, finding that the group home violated the restrictive covenant and issued a permanent injunction against its operation (paras 4-5).
Parties' Submissions
- Appellant (Community of Damien of Molokai): Argued that the group home complied with the restrictive covenant as it constituted a residential use and that enforcing the covenant against the group home violated the Federal Fair Housing Act (FHA) (paras 1, 4-5).
- Appellees (Neighbors): Contended that the group home violated the covenant's "single-family residence" requirement, as the residents were unrelated, and that the increased traffic negatively impacted the neighborhood (paras 3-4, 22-23).
Legal Issues
- Did the operation of the group home violate the restrictive covenant requiring "single-family residence purposes"?
- Did the enforcement of the restrictive covenant against the group home violate the Federal Fair Housing Act?
Disposition
- The Supreme Court of New Mexico reversed the district court's decision, holding that the group home did not violate the restrictive covenant and that enforcing the covenant would violate the FHA (paras 1, 52).
Reasons
Per Frost J. (Baca C.J., Ransom, Franchini, and Minzner JJ. concurring):
Interpretation of Restrictive Covenant:
The court found that the group home constituted a residential use under the covenant. The residents lived as a family unit, sharing meals, providing mutual support, and maintaining a family-like atmosphere. The covenant's language did not explicitly exclude unrelated individuals living together as a family (paras 7-11).
Additionally, the term "family" was ambiguous and should be interpreted broadly to include unrelated individuals living as a cohesive unit, consistent with public policy favoring integration of disabled individuals into communities (paras 12-19).
Impact of Increased Traffic:
The court held that the increased traffic generated by the group home was irrelevant to determining whether the covenant was violated, as the covenant did not regulate traffic or parking. The traffic did not alter the residential nature of the home (paras 22-25).
Fair Housing Act (FHA):
The court concluded that enforcing the covenant against the group home would violate the FHA.
- Disparate Impact: The covenant disproportionately affected disabled individuals who require group living arrangements, creating a barrier to housing access (paras 34-42).
- Reasonable Accommodation: The neighbors failed to make reasonable accommodations under the FHA by enforcing the covenant, as nonenforcement would not impose undue burdens or fundamentally alter the covenant's purpose (paras 43-48).
Counterclaim:
The court affirmed the dismissal of the Community's counterclaim for attorney's fees and a permanent injunction, finding no evidence of future violations by the neighbors (paras 50-51).
The court emphasized the strong public policy favoring the integration of disabled individuals into residential communities and the FHA's role in removing barriers to housing for such individuals (paras 49, 52).