Case Law Reference
Michigan court decisions that shape what Woodbine can and can't do.
Amendment & Consent
Conlin v. Upton
313 Mich App 243 (2015)No new covenant binds an owner without that owner's consent. A release provision is not an amendment provision.
Controlling authority. Woodbine has no amendment provision — only a 75% release provision. Mandatory dues cannot be imposed without unanimous consent of all 140 homeowners.
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The Court of Appeals held that where original covenants contain only a release provision (allowing removal of restrictions), adding any new obligation requires unanimous consent. This is the case that most directly applies to Woodbine's dues situation.
Ardmore Park Subdivision Ass'n v. Simon
117 Mich App 57 (1982)Where original covenants contain an amendment provision specifying a percentage, dissenting owners are bound by properly passed and recorded amendments.
Shows the contrast — Woodbine's restrictions lack such a provision, which is exactly why unanimous consent is required.
Association Standing
Civic Association of Hammond Lake Estates v. Hammond Lake Estates No. 3
271 Mich App 130 (2006)A voluntary HOA with only ~65-70% membership has standing to enforce recorded deed restrictions in court.
Directly applicable. The WIA has standing to enforce existing restrictions even without 100% membership. Any individual lot owner also has independent standing.
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This case is good news for Woodbine — it means the WIA can take legal action to enforce the existing deed restrictions (residential use, architectural control, etc.) without needing every homeowner to be a member.
Short-Term Rentals
Melvin R. Berlin Revocable Trust v. Rubin
Mich. Supreme Court, July 2025Affirmed (3-3 equal division) that 'single family residence purposes' covenant prohibits STRs. Court of Appeals rulings now binding statewide.
Woodbine's 'private residence purposes only' language is virtually identical. If the restrictions are enforceable, the existing language would prohibit Airbnb/VRBO under this ruling.
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The Michigan Supreme Court's equal division (3-3) means the Court of Appeals decision stands and is binding statewide. This is the most important STR case for Woodbine.
Eager v. Peasley
322 Mich App 174 (2017)Renting property for short-term use is a commercial use, even if the activity occurring on the property is residential in nature.
Establishes the key principle: the nature of the rental transaction (short-term, profit-driven) makes it commercial regardless of what tenants do on the property.
Aldrich v. Sugar Springs
345 Mich App 181 (2023)'Residential purposes only' restriction alone — even without explicit commercial-use prohibition — suffices to bar STRs.
Removes any argument that explicit anti-commercial language is needed. If enforceable, Woodbine's existing residential-use restriction would be sufficient — no additional anti-commercial language needed.
Timber Lake Drive v. Gribi
COA, Sept. 2025Even long-term rentals can violate commercial-use restrictions when the owner treats property purely as a profit-making enterprise.
Extends the principle beyond short-term rentals to any purely commercial rental operation.
Alienation & Restraints
Sanborn v. McLean
233 Mich 227 (1925)Restrictions in a common development scheme bind all lots if subsequent purchasers have actual or constructive notice (reciprocal negative easements).
Supports enforceability of Woodbine's uniform scheme — all lots are bound even if a specific lot's deed doesn't explicitly mention the restrictions.
Mandlebaum v. McDonell
29 Mich 78 (1874)Michigan has a firm stance against restraints on alienation.
Direct prohibitions on resale (anti-flipping covenants, minimum hold periods) would likely be struck down.
LaFond v. Rumler
Mich. COAProfit-sharing clauses on early resale are unreasonable restraints on alienation.
Minimum hold periods, rights of first refusal, or anti-flipping provisions would similarly be invalidated.