The case involves an appeal regarding the defendant's intention to convert fourteen former motel units into dwelling houses on property subject to a deed restriction prohibiting the use of mobile homes, trailers, shacks, or tents as structures. The trial court had issued an injunction against the defendant, citing this restriction. The defendant argued that his units, which he planned to modify by placing them on a foundation and removing their wheels, should not be classified as prohibited structures under the deed, claiming they are "modular building units" rather than mobile homes or trailers.
The appellate court reviewed the trial court's findings, emphasizing that restrictions on property use are strictly construed based on the parties' intent. The court noted that the definitions of "mobile homes" and "trailers" differ in Tennessee law, with the defendant asserting that his units fit the modular definition, which is distinct from mobile homes. However, the evidence indicated that the units shared characteristics of both mobile homes and modular units. The appellate court upheld the trial court's decision, relying on precedent cases for interpreting the restrictions and affirming the injunction against the defendant’s intended use of the units.
Defendant's units, which were pre-assembled and mounted on a chassis for travel on public highways, were identified as mobile homes. In the case of Albert, the court addressed a structure comprising two large units towed to a site and subsequently placed on concrete footers, with wheels and axles removed. The court ruled that the differences between this structure and a mobile home were insignificant. In Beacon Hills, the court evaluated a manufactured home, contrasting its definition with that of a mobile home under Tennessee law. The conclusion was that the proposed structure met the criteria for both definitions, asserting that distinctions between manufactured and mobile homes are irrelevant. The defendant sought to adopt a different rationale from Brasher v. Grove, which supported a minority view allowing certain units to be used as dwellings despite deed restrictions against trailers. However, the court adhered to the majority view established in Albert and Beacon Hill, asserting that aesthetic modifications do not negate the intent of land restrictions. The Chancellor determined that the defendant's units had characteristics synonymous with mobile homes, which were intended to be excluded by deed restrictions. The court affirmed the trial court's findings, ruling that the evidence supported the Chancellor's decision, with costs of the appeal assigned to the appellant. The majority view maintains that a mobile home retains its classification regardless of exterior modifications or foundation placement.
