Dodge v. Carauna

Joseph and Jewell Carauna appeal from a judgment directing the removal or modification of a backyard playhouse, and from an oral contempt order arising from their failure to do either. The issues are whether a private deed restriction containing no specific standards of approval is enforceable; whether testimony regarding similar unapproved structures on other lots is relevant; and whether the trial court erred in finding appellants in contempt of court. Because we conclude that the court's findings regarding the reasonableness of the enforcement of the deed restriction were inadequate, we…