## Facts

- A residential subdivision in Suffolk County, New York was developed under a common scheme beginning in 1945, with deeds containing identical restrictive covenants limiting structures to “single family dwellings.”
- The covenant’s purpose was to preserve the subdivision’s single-family residential character and exclude uses inconsistent with a quiet residential setting.
- In 1980, a nonprofit service provider leased a six-bedroom house in the subdivision to operate a community residence for eight developmentally disabled adults who previously lived in institutions.
- The residents lived in a home-like environment, sharing meals and common areas, with continuous professional supervision and therapy services.
- Neighbors objected and the property owners’ association sued to enforce the covenant and enjoin the residence, arguing it was not a “single family dwelling.”

## Issues

1. Whether a supervised community residence for eight developmentally disabled adults is a “single family dwelling” within the meaning of a private restrictive covenant.
2. If the use falls outside the covenant, whether enforcement to exclude the residence is barred by New York public policy favoring community-based housing for developmentally disabled persons.

## Decision

- The Court of Appeals affirmed dismissal of the complaint.
- The court held the residence qualified as a “single family dwelling” because it functioned as a single, stable housekeeping unit.
- The court further held that, even if the covenant were read to exclude the residence, enforcing it to bar this use would contravene strong state public policy supporting deinstitutionalization and community placement.

## Legal Principles

- “Single family dwelling” and similar terms may be construed by functional household characteristics (living together as one housekeeping unit), not limited to occupants related by blood, marriage, or adoption.
- Restrictive covenants are disfavored and strictly construed; doubts are resolved against enforcement.
- A private covenant will not be enforced where enforcement would frustrate clearly expressed state public policy, including statutory policies supporting integrated community residences for persons with developmental disabilities.
- The presence of supervisory staff and program services does not necessarily convert an otherwise residential use into a prohibited commercial or institutional use where occupancy is stable and the home operates like a household.

## Conclusion

The court permitted a supervised group home to remain in a single-family subdivision by construing “single family dwelling” to include a stable, single-housekeeping-unit community residence and by declining to enforce private restrictions in a manner inconsistent with New York’s policy favoring community integration of developmentally disabled individuals.


Crane Neck Ass’n, Inc. v. N.Y.C./Long Island Cnty. Servs. Grp., 61 N.Y.2d 154, 460 N.E.2d 1336 (N.Y. 1984)