A recent San Diego County court ruling has sent ripples through California's housing landscape — and if you own or manage property in an HOA community, it's worth paying close attention.
In a case that dragged on for over a year, a Carlsbad condo owner named Adam Hardesty attempted to convert his garage into a rental unit, citing a 2019 California state law designed to make it easier to build accessory dwelling units (ADUs). The HOA pushed back, arguing its rules prohibited using garages for anything other than car storage. In April, Superior Court Judge Victor Torres sided with the HOA.
Why Did the HOA Win?
The ruling hinged on a technical but important distinction: the 2019 ADU law, the court found, applies to areas "zoned only for single-family residential use." Because Hardesty's Mystic Point community included townhomes and small condos alongside single-family homes, the judge determined the law didn't apply. The Legislature, Torres noted, could have written the law to explicitly include condos — but didn't.
What This Means for Property Owners and Managers
For anyone managing properties within an HOA — or advising clients who own them — this case is a cautionary tale. State housing law and HOA governing documents don't always align neatly, and the courts may not automatically side with homeowners seeking to add rental units, even when state law appears to support them.
That said, this likely isn't the final word. Hardesty indicated he wants to appeal, and the judge himself acknowledged the complexity, noting he expected to "hear more education from the Court of Appeal at some point." The legal landscape around ADUs continues to evolve rapidly.
At Monterey Bay Property Management, we stay ahead of exactly these kinds of developments so our property owners don't have to. If you have questions about ADU regulations, HOA compliance, or how recent legal shifts may affect your investment property, we're here to help.
