AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

• The Roybals, owners of a 4.618-acre lot in the DeVargas Development Company Subdivision No. 2 in Santa Fe, New Mexico, constructed a large garage on their property to house a car collection. The garage, designed in the Old Santa Fe style to match the existing house, was challenged by their neighbor, Sabatini, who filed a complaint alleging the construction violated restrictive covenants applicable to the subdivision. These covenants limited constructions to a private dwelling house, guest house, and a private garage, without explicitly defining the size or capacity of a "private garage" (paras 2-4).

Procedural History

• District Court of Santa Fe County: Granted an injunction requiring the Roybals to reduce in size or eliminate the garage, ruling it did not qualify as a "private garage" under the subdivision's restrictive covenants.

Parties' Submissions

• Roybals: Argued that their garage, designed to house a car collection and conforming to the Old Santa Fe style, qualified as a "private garage" under the restrictive covenants (paras 3, 5).
• Sabatini: Contended that the Roybals' garage violated the restrictive covenants by exceeding what he considered a reasonable size for a "private garage" intended for use by a single-family residence (para 4).

Legal Issues

• Whether the district court erred in construing a restrictive covenant allowing a "private garage" to mean only those garages capable of holding no more than a reasonable number of vehicles for the use of a single family (para 1).

Disposition

• The Court of Appeals reversed the district court's decision, holding that the term "private garage" contains no size limitation and that the Roybals' garage qualifies as a "private garage" under the restrictive covenants (para 17).

Reasons

• Per Michael D. Bustamante, J. (Cynthia A. Fry, J., Michael E. Vigil, J., concurring): The Court found that the district court incorrectly applied standards for construing terms in restrictive covenants by imposing a size limitation on what constitutes a "private garage." The term "private garage" was deemed ambiguous because it is susceptible to multiple interpretations and the covenants did not explicitly limit the size of such a structure. The Court applied rules of interpretation favoring the free use of property and against reading restrictions into covenants by implication. It concluded that a "private garage" refers to a structure whose essential purpose is the storage of motor vehicles by the owners and not by the general public, without any size limitation. Therefore, the Roybals' garage, primarily designed to store vehicles and not available to the general public, fits within the meaning of "private garage" as intended by the restrictive covenants (paras 5-16).