## Facts

- Jonathan and Megan Blood bought a home in the Stoneridge at Fountain Green community in Harford County, Maryland, subject to a recorded declaration and design guidelines enforced by the homeowners association (HOA).
- The declaration required prior written approval from the HOA for exterior changes and stated that approval could not be unreasonably withheld.
- Community rules prohibited solar panels on the front roof while allowing panels on the back roof.
- Seven homes in the community had solar panels, all installed on back roofs only.
- The Bloods installed a 48-panel rooftop system without prior approval: 15 panels on the front roof and 33 on the back roof.
- After installation was nearly complete, the Bloods applied for approval; the HOA denied the application because of the front-roof placement.
- The HOA demanded removal of the 15 front-roof panels; the Bloods refused.
- The HOA sued for declaratory relief and an injunction requiring removal of the front-facing panels; the circuit court granted both forms of relief.
- On appeal, the Bloods relied primarily on Maryland Real Property § 2-119(b), which bars covenants restricting solar collectors except for “reasonable restrictions,” defined by a cost/efficiency standard.

## Issues

1. Whether a covenant banning solar panels on front roofs (but allowing them on back roofs) constituted an “unreasonable restriction” under Maryland Real Property § 2-119(b) by significantly increasing system cost or significantly decreasing efficiency.
2. Whether the HOA unreasonably withheld approval under the declaration when it denied the Bloods’ application and required removal of the front-roof panels.

## Decision

- The Appellate Court of Maryland affirmed the circuit court’s declaratory judgment and injunction.
- The front-roof prohibition was not shown to be an “unreasonable restriction” under RP § 2-119(b) because the Bloods did not prove that rear-only placement would significantly increase cost or significantly decrease efficiency.
- The HOA did not unreasonably withhold approval by enforcing a clear, uniformly applied restriction that was in effect when the Bloods purchased the property.
- The injunction requiring removal of the 15 front-roof panels remained in effect; the Bloods could keep the 33 rear-roof panels.

## Legal Principles

- Under Maryland Real Property § 2-119(b), HOA covenants affecting solar collector systems are invalid only if they impose “unreasonable restrictions,” meaning restrictions that significantly increase cost or significantly decrease efficiency.
- Location and aesthetic restrictions on solar panels are not per se unlawful; validity turns on the statute’s cost/efficiency threshold.
- The homeowner bears the burden to prove significant cost increase or efficiency decrease under RP § 2-119(b).
- An HOA generally does not “unreasonably withhold” architectural approval when it denies an application to enforce a facially valid, clearly stated, and consistently enforced covenant.

## Conclusion

The court held that Maryland’s solar-access statute limits HOA authority only to the extent a restriction materially impairs solar cost or efficiency, and because the homeowners failed to prove that rear-only placement met that threshold, the HOA could enforce its front-roof ban and obtain an injunction requiring removal of the front-facing panels.


Blood v. Stoneridge at Fountain Green Homeowners Ass'n, Inc., 242 Md. App. 417 (2019)