Manchester Oaks Homeowners Association, Inc. v. Batt

Fairfax · VA · Supreme Court of Virginia

Member win · other

What happened

Manchester Oaks had 30 garaged and 27 ungaraged townhouses plus 72 common-area spaces. After years of first-come visitor parking, the HOA reserved two spaces for each ungaraged lot and later purported to amend the declaration to authorize preferential assignment. Garaged-lot owners Batt, Grom, and Martin sued for breach. The circuit court awarded relief; on September 14, 2012, the Virginia Supreme Court largely affirmed equal-parking and amendment rulings, trimming some damages.

What the court (or agency) held

The Virginia Supreme Court held that common-area parking must be assigned equally among all lot owners unless the declaration expressly says otherwise. A later amendment trying to license two reserved spaces only to ungaraged lots was invalid (the association failed to challenge every independent ground for that ruling, including inadequate meeting notice). The Court trimmed speculative lost-value damages but affirmed compensatory awards for common-area maintenance assessments paid while the owners were denied equal parking, plus prevailing-party fees as appropriate.

Why this matters for members

This result is MIXED — a partial win, not a clean sweep on every claim. Equal common-area easements cannot be reallocated by board practice or a defective amendment that prefers some lots. Meeting-notice defects and failure to challenge independent grounds on appeal can lock in an invalid-amendment ruling.

What the member did

Sued to enforce the declaration's equal common-area easement, challenged the purported amendment, and sought statutory fees as the prevailing party.

What did not work

Large lost-value damages based on an HOA website post were reversed as unsupported; Martin's tax-apportionment damages were also reversed as outside the pleadings.

Questions for the board

Questions for a lawyer

Citation

Manchester Oaks Homeowners Association, Inc. v. Batt, 732 S.E.2d 690 (Va. 2012); Record No. 111949 (2012-09-14). Supreme Court of Virginia. Outcome chip: MIXED. Flags: MIXED. Source: https://www.vacourts.gov/static/opinions/opnscvwp/1111949.pdf

_General information, not legal advice. Outcomes turn on facts and current law._

Source opinion

General information, not legal advice. Outcomes turn on facts and current law.

Not a law firm. Not legal advice. Confirm this against your documents and your state’s law.