Homeowners Association Blocked Their Garage Over an RV-Sized Door — Then the Appeals Court Ruled It Broke Its Own Promise and Ordered Judgment for Them

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Most homeowners don’t move into a planned community expecting a courtroom fight over a garage door. They expect the usual stuff: the neighbor who mows at 7 a.m., the endless debate about paint colors, and maybe a stern letter if the trash cans sit out too long. Alfred and Joan Santoro expected something else, too—something the community’s own rules seemed to promise.

In a decision from the Oregon Court of Appeals, the Santoros won a second trip up the appellate ladder after their homeowners association blocked plans for a garage with a 12-foot door meant to fit a recreational vehicle. The court ruled the HOA broke its contractual duty to act in good faith and sent the case back with instructions to enter judgment for the homeowners. The opinion is laid out in the source material, and it’s a solid reminder that “aesthetic discretion” isn’t a magic wand.

If you’ve ever dealt with an HOA, you know the tension. The group wants uniformity and curb appeal, and homeowners want to actually live on their property. Most of the time, you can work it out with a conversation and some humility. Sometimes, though, the paperwork matters more than anyone wants to admit.

The setup: CC&Rs, a review committee, and a 12-foot garage door

The Santoros bought a lot in Eagle Crest, a planned residential community governed by recorded covenants, conditions, and restrictions—CC&Rs. Those CC&Rs created an HOA and an architectural review committee, and they required homeowners to submit construction plans for approval before building.

Back in 2016, the Santoros submitted plans that included a garage with a 12-foot door—big enough to accommodate an RV. The committee conditionally approved the plans, but only if the Santoros made two changes: swap the oversized door for a standard door no taller than eight feet, and reduce some driveway paving. The committee cited “aesthetic reasons” and pointed to a CC&R provision giving it broad authority to evaluate exterior design harmony.

The homeowners appealed inside the HOA structure, arguing that neither the CC&Rs nor the committee’s guidelines expressly prohibited oversized garages, and that other homes in the community had RV garages. The committee unanimously denied the appeal, and the dispute moved from neighborhood politics to contract law.

Why an HOA dispute turned into a contract case

The legal framing mattered. The Santoros sued for breach of contract and declaratory judgment, arguing that the CC&Rs imposed an affirmative duty of good faith on the committee and that the committee violated that duty by denying the RV garage.

After a bench trial, the trial court originally sided with the HOA. It found the committee had broad authority under the CC&Rs, and it accepted the committee’s explanation that the oversized garage was inconsistent with the community’s overall character. The trial court concluded the Santoros hadn’t shown fraud, bad faith, or lack of honest judgment, so the HOA hadn’t breached the contract.

That kind of ruling is common in HOA fights: “They had discretion, they used it, end of story.” But the Oregon Court of Appeals didn’t let it stop there the first time this case came up.

The first appeal: “Good faith” isn’t just “not bad faith”

In the first appeal (referred to in the later opinion as Santoro I), the Court of Appeals held that the CC&Rs contained an express obligation requiring the committee to act in good faith. The trial court had treated the issue like it was only about whether the HOA acted dishonestly or with outright bad intent. The Court of Appeals said that was the wrong legal standard.

The appellate court emphasized a key point drawn from Oregon contract law: good faith isn’t satisfied just because someone acts honestly. If a party is given discretion under a contract, that discretion must be exercised for purposes the parties contemplated. Using discretion to “evade the spirit of the bargain” can still be bad faith, even if nobody is lying.

The case went back to the trial court to reconsider the decision under the correct good-faith framework. No retrial happened; both sides agreed the existing record was enough, and they argued it out through briefing and oral argument.

The CC&R promise that changed everything: RVs must be in enclosed garages

On remand, the Santoros leaned hard on a specific CC&R provision: section 4.9, titled “Vehicles and Parking.” That section restricted certain vehicles—including recreational vehicles over a certain weight—from being kept, placed, maintained, or parked for more than a short period anywhere on the property “except in enclosed garages” (or in other designated or screened areas approved by the architectural committee).

The homeowners’ point was straightforward. If the rules require RVs to be stored in enclosed garages, then homeowners should reasonably be able to build a garage that can actually hold an RV. The Santoros also pointed to other CC&R sections limiting the committee’s authority—one saying committee decisions must be in good faith and “may not violate” the declaration, and another stating the committee’s authority can’t be construed to modify, alter, or waive CC&R provisions.

The HOA answered with a familiar argument: section 4.9 lets you store an RV in a garage, but it doesn’t require the HOA to approve a particular kind of garage door. In other words, permission to do a thing isn’t the same as a guarantee that you can build whatever you want to make that thing easy.

The trial court doubled down, and the appellate court wasn’t having it

The trial court again sided with the HOA. It adopted its earlier findings and again concluded the committee denied the plans because the oversized door would disrupt the community’s appearance and “create disunity.” The trial court decided the HOA acted as could reasonably be expected, performing its role of preserving harmony of external design, and therefore acted in good faith.

The Oregon Court of Appeals agreed with the HOA on one limited point: denying the 12-foot door did not, as a pure matter of contract interpretation, “violate, modify, alter, or waive” section 4.9. The court acknowledged that section 4.9 authorizes RV parking in enclosed garages, but it doesn’t explicitly require the committee to approve every design choice needed to make that happen.

But then the court turned to the heart of the case: good faith. And that’s where the HOA lost.

The core ruling: good faith can’t be used to quietly erase the deal

The appellate court said the parties were arguing past each other. The Santoros weren’t claiming the HOA had to approve every RV garage design under the sun. They were claiming something more modest and more reasonable: the CC&Rs created an expectation that homeowners would be allowed to build some garage design that could actually store an RV.

The court noted an undisputed practical reality: an RV can’t fit through an eight-foot garage door. If the committee denies a 12-foot door because it dislikes how it looks, it isn’t just choosing a style. It is effectively preventing homeowners from doing what the CC&Rs contemplate—owning an RV and storing it in an enclosed garage.

That’s the line the court drew. The committee’s discretion had to be exercised consistently with the reasonable expectations arising from the CC&Rs. The HOA could pursue aesthetics, and it could be honest about it, but it couldn’t use aesthetics as a backdoor way to effectively ban RV garages altogether. The Court of Appeals held that, applying the correct legal principles to the undisputed facts, the only conclusion was that the HOA breached its contract by denying the RV-size door. It reversed and remanded with instructions for judgment in the Santoros’ favor, leaving the trial court to sort out remedies.

What this means for people living under HOA rules

This ruling won’t end HOA conflicts. There will always be somebody trying to build something that looks like it belongs on a different street, and there will always be committees that get drunk on tiny bits of power. The more interesting point here is that written promises in CC&Rs have weight, and “we didn’t like the look of it” doesn’t automatically outrank the rest of the document.

If a community’s rules steer homeowners toward a certain lifestyle—like requiring RVs to be stored in enclosed garages—then the enforcement side can’t turn around and make that lifestyle functionally impossible through discretionary “aesthetic” decisions. That’s not order; that’s bait-and-switch. And courts tend to notice when a party uses discretion to dodge the spirit of the deal it signed up to administer.

For homeowners, it’s also a reminder to read what you’re buying into. CC&Rs aren’t light reading, but neither is years of litigation. And for HOAs, it’s a reminder that leadership is stewardship, not domination; people can live with rules when the rules are coherent and applied with fair-minded restraint.

The Santoros didn’t win because a judge decided RV garages are beautiful. They won because the HOA’s own promises created a reasonable expectation, and the committee’s discretion couldn’t be used to quietly cancel that promise. That’s a pretty clean principle, and it’s one worth keeping in mind the next time someone says, “We can do whatever we want—it’s for the aesthetics.”