Varsity Park Estates Homeowners Assn. v. Anglin CA2/6

California Court of Appeal Jan 28, 2026 No. B343731Unpublished

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Holding. The court held that homeowners association (HOA) use restrictions are presumptively valid and that the burden of proof rests on the challenging homeowner to demonstrate that an HOA's enforcement decision was arbitrary, made in bad faith, or unreasonable. The court further held that the HOA was not equitably estopped from enforcing the restriction because the homeowners failed to prove the HOA knowingly waived the restriction or had the authority to do so.

Issues

Whether the trial court erred in placing the burden of proof on the homeowners to show that the HOA's enforcement of a parking restriction was arbitrary or in bad faith.
Whether the HOA is equitably estopped from enforcing a parking restriction after approving an architectural application that did not explicitly request a waiver of said restriction.

Disposition. affirmed

Quotations verified verbatim against the opinion

“use restrictions are “presumptively valid, and the burden of proving otherwise rests upon the challenging homeowner””

“The trial court did not err in assigning to appellants the burden to prove respondent acted arbitrarily.”

“the HOA board, sitting as the architectural committee, lacked authority under the CC&Rs to waive enforcement of the parking restriction, absent an amendment to the CC&Rs.”

Filed 1/28/26 Varsity Park Estates Homeowners Assn. v. Anglin CA2/6 NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

SECOND APPELLATE DISTRICT

DIVISION SIX

VARSITY PARK ESTATES 2d Civil No. B343731 HOMEOWNERS ASSOCIATION, (Super. Ct. No. 2023CUCO007971) Plaintiff and Respondent, (Ventura County)

JAMES D. ANGLIN, et al.,

Defendants and Appellants.

Appellants James Anglin and Kimberly Crane own a home in a Moorpark common interest development that is governed by a homeowners association, respondent Varsity Park Estates Homeowners Association (respondent or the HOA), and a set of recorded Covenants, Conditions and Restrictions (CC&Rs). The HOA sued appellants to enforce a CC&R that prohibits parking a recreational vehicle in the community. After a non- jury trial, the trial court entered judgment in favor of respondent, finding the parking restriction was enforceable and that respondent had not made an arbitrary decision to enforce it

against appellants. They contend the trial court erred in placing the burden of proof on appellants to prove the restriction is arbitrary or was arbitrarily enforced. Appellants further contend the HOA is estopped to enforce the restriction because it approved their application to relandscape and install gates on their property. We affirm. Facts The use restriction at issue here provides, “2.6 Parking Restrictions. No mobile home, cab-over camper, tent, machinery, construction equipment, boat, truck, trailer, recreational vehicle, inoperable or dilapidated vehicle, or commercial vehicle of any kind shall be kept, stored or parked (other than temporarily), maintained, constructed, or repaired, on any property within the Development; provided, however, that the provisions of this Section shall not apply to emergency vehicle repairs . . . . This Section may be changed only with the vote or consent of two-thirds (2/3) of the voting membership.” In 2014, appellants purchased a camping trailer. When they realized the CC&Rs prohibited them from parking it on their property, they spoke with the then president of the HOA board of directors. Appellants understood they could obtain permission to park the trailer on their property by submitting an application to the HOA’s architectural committee. Appellants submitted an application to re-landscape their front and back yards and install gates in their back yard. The fax cover sheet attached to their application stated that they were adding the gates, “for parking a camping trailer the affected neighbors . . . have given signed approval.” The application itself, however, did not mention parking a trailer on the property. The HOA’s board of directors, sitting as the architectural committee,

Varsity Park Estates Homeowners Assn. v. Anglin CA2/6

AI Brief

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

SECOND APPELLATE DISTRICT

DIVISION SIX

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