## Facts

- Lincoln Heights (Auditor’s Plat 120) was a platted area of 31 lots about five miles east of Cedar Rapids, developed and marketed as a restricted residential district.
- Deeds in the subdivision’s chain of title included covenants limiting lots to “private residence purposes only,” along with related building-location and dwelling limitations.
- Carlton J. Korff and Lula Belle Korff bought Lot 31, an 8.2-acre corner lot with an existing dwelling, taking title subject to recorded restrictions.
- The Korffs began grading and road work to operate an auto trailer court from their dwelling on Lot 31.
- Ross E. Grange and other lot owners, joined by intervenors owning an adjoining lot, sued in equity to enjoin the trailer court as violating the subdivision restrictions.
- The Korffs argued the restrictions were not enforceable by other owners and, alternatively, should not be enforced due to alleged changed conditions (sewage routing/odor, a small kennel-related activity and sign, and abandonment of a nearby railroad line).

## Issues

1. Whether the subdivision restrictions were part of a general plan intended to benefit all lots, making them enforceable by other lot owners rather than merely personal to the original grantor.
2. Whether alleged neighborhood changes were so substantial as to defeat the purpose of the restrictions and justify denying injunctive relief.
3. Whether equitable enforcement required reading the restrictions to limit Lot 31 to a single dwelling, or permitting more than one dwelling while preserving the residential-use limitation.

## Decision

- The Iowa Supreme Court held the restrictions reflected a general residential plan and were enforceable by other lot owners against Lot 31.
- The court held the Korffs were bound by the restrictions because they took title with at least constructive notice from the recorded chain of title.
- The court rejected the “changed conditions” defense, finding no fundamental change that defeated the restrictions’ residential purpose.
- The court affirmed an injunction barring operation of an auto trailer court on Lot 31 as inconsistent with “private residence purposes only.”
- The court modified the decree to permit more than one dwelling on Lot 31, given its size, while maintaining the prohibition on nonresidential use.
- Disposition: affirmed as modified.

## Legal Principles

- Subdivision restrictions imposed under a general plan for the benefit of the platted lots may be enforced by individual lot owners against other lots in the plan.
- A purchaser with actual or constructive notice of recorded restrictive covenants is bound in equity to comply with them.
- Changed conditions defeat enforcement of a restrictive covenant only when the change is substantial and defeats the covenant’s original purpose; isolated or minor deviations do not suffice.
- Equity may enforce the core objective of a restrictive scheme (residential character) while modifying or construing ancillary details to avoid undue hardship inconsistent with the scheme’s intent.

## Conclusion

The court enforced Lincoln Heights’ reciprocal residential covenants to enjoin a trailer court on Lot 31, found no sufficiently fundamental neighborhood change to bar enforcement, and modified the decree to allow multiple residential dwellings on the unusually large lot while keeping the noncommercial residential-use restriction intact.


Grange v. Korff, 79 N.W.2d 743 (Iowa 1956)