Forbush v. Hamilton Cove Homeowners Assn. CA2/5

CourtCalifornia Court of Appeal
DecidedApril 4, 2025
DocketB334724
StatusUnpublished

This text of Forbush v. Hamilton Cove Homeowners Assn. CA2/5 (Forbush v. Hamilton Cove Homeowners Assn. CA2/5) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Forbush v. Hamilton Cove Homeowners Assn. CA2/5, (Cal. Ct. App. 2025).

Opinion

Filed 4/4/25 Forbush v. Hamilton Cove Homeowners Assn. CA2/5 NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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 FIVE

MARC FORBUSH et al., B334724

Plaintiffs and Appellants, (Los Angeles County Super. Ct. No. v. 22LBCV00529)

HAMILTON COVE HOMEOWNERS ASSOCIATION,

Defendant and Respondent.

APPEAL from a judgment of the Superior Court of Los Angeles County, Michael Vicencia, Judge. Affirmed. The Perry Law Firm, Michael R. Perry, Larry M. Roberts and Matthew J. Bertolucci for Plaintiffs and Appellants. Moskovitz Appellate Team, Myron Moskovitz and Jason R. Marks; Biston-Gubernick and Jeffrey S. Gubernick for Defendant and Respondent. ________________________ Plaintiffs and appellants Marc Forbush and Carol Forbush appeal from a portion of a judgment entered in favor of defendant and respondent Hamilton Cove Homeowners Association (the HOA) in this action arising out of the HOA’s denial of proposed modifications to the Forbushes’ units. The trial court found the HOA’s refusal to consider a request for an interior elevator at the first stage of architectural review was unreasonable, but found the HOA acted reasonably in denying requests to construct an exterior elevator and an interior hallway that would have required granting the Forbushes exclusive use of common areas. On appeal, the Forbushes assert, among other contentions, that the HOA’s denial of the proposed modifications was arbitrary and capricious, failed to adhere to the governing documents, and violated California laws allowing modifications to accommodate disabilities. We conclude the trial court’s findings that the HOA acted reasonably are supported by substantial evidence: California law does not require the HOA to allow modification to accommodate the potential disabilities of potential renters, the trial court’s finding that certain utility pipes behind the walls of the Forbushes’ units are located in common areas was supported by substantial evidence, and the HOA did not act unreasonably by refusing to grant the Forbushes exclusive use of those common areas. Because the HOA did not act unreasonably in denying these modifications at the first stage of the architectural review, they were not required to proceed to a second stage of review as to these proposals. Therefore, we affirm.

2 FACTS

I. Hamilton Cove

Hamilton Cove is a condominium development on Catalina Island with 185 units in multiple buildings. Building 8 contains 18 units “stair-stepped” on a hillside, with part of each lower unit forming the floor and balcony of the unit above. The HOA is governed by a five-member board of directors (the board) and regulated by the Restated Declaration of Covenants, Conditions and Restrictions and Reservation of Easements for Hamilton Cove as amended December 1, 2018 (the CC&Rs). The CC&Rs define a “unit” as “a living area space or spaces (‘Residential Element’) bounded by and contained within the interior unfinished . . . surfaces of the perimeter walls, floors, ceilings, windows and doors of each Residential Element, as shown and defined in the Condominium Plan. In interpreting deeds, declarations and plans, the existing physical boundaries of the Unit or a Unit constructed or reconstructed in substantial accordance with the Condominium Plan . . . shall be conclusively presumed to be its boundaries, rather than the description expressed in the deed, Condominium Plan, Original Declaration, or this Restated CC&Rs, . . . regardless of minor variances between boundaries as shown on the Condominium Plan . . . . In simple language, a ‘Unit’ is everything inside the walls of a Condominium which is the sole property of a sublessee or fee simple owner. A sublessee or fee simple owner has an undivided

3 interest in the walls and Improvements in the Increment where the Unit is located.” The “common areas” of the complex include, “without limitation, for maintenance purposes of the Association, but not necessarily by way of fee title, all gas, water and waste pipes, all sewers, all ducts, chutes, conduits, wires, and other utility installations of the Project Improvements wherever located . . . .” The board appoints a three-member architectural committee (the committee) to review proposals to modify units. No construction or alteration of an improvement may be commenced until plans and specifications showing the nature, kind, shape, height, width, color, materials and location have been submitted to the committee and received approval in writing. The committee “shall approve proposals or plans and specifications submitted for its approval only if it deems that the construction, alternations, or additions contemplated thereby in the locations indicated will not be detrimental to the appearance of the surrounding area of the Project as a whole, that the appearance of any structure affected thereby will be in harmony with the surrounding structures, that the construction thereof will not detract from the beauty, wholesomeness and attractiveness of the Common Property or the enjoyment thereof by the Members . . . .” The committee’s approval of a proposal in connection with another matter cannot be deemed to be a waiver of the right to withhold approval or consent to similar proposals, plans and specifications, drawings or matter subsequently or additionally submitted for approval. The CC&Rs limit the scope of the committee’s review: “The Architectural Committee shall review and approve or disapprove

4 all plans submitted to it for any proposed Improvement, alteration or addition, on the basis of aesthetic considerations, consistency with the Restated CC&Rs, and the overall benefit or detriment which would result to the immediate vicinity and the Project generally. The Architectural Committee shall take into consideration the aesthetic aspects of the architectural designs, placement of buildings, landscaping, color schemes, exterior finishes and materials and similar features. The Architectural Committee’s approval or disapproval shall be based solely on the considerations set forth in this Article IV, and the Architectural Committee shall not be responsible for reviewing, nor shall its approval of any plan or design be deemed approval of, any plan or design from the standpoint of structural safety or conformance with building or other codes.” The CC&Rs also provide that “no exterior addition, change or alteration to any Condominium or Residence shall be commenced without the prior written approval of the Architectural Committee. Nothing shall be done in any Condominium or in, on or to the Common Areas which will or may tend to impair the structural integrity of any building in the Project or which would structurally alter any such building except as otherwise expressly provided herein.” The committee has interpreted this provision to preclude approval of alterations which would impair the structural integrity or would structurally alter any building in the project unless provided for in the CC&Rs. The committee’s recommendations are subject to independent reconsideration by the board. In addition to the CC&Rs, the owners are governed by the revised and restated Rules and Regulations & Security Guard

5 Guidelines (the rules). The rules state that “[t]he Committee shall utilize a two-stage approval process. The Owner’s preliminary submission shall include sketches and a description of the work.

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Cite This Page — Counsel Stack

Bluebook (online)
Forbush v. Hamilton Cove Homeowners Assn. CA2/5, Counsel Stack Legal Research, https://law.counselstack.com/opinion/forbush-v-hamilton-cove-homeowners-assn-ca25-calctapp-2025.