Constant v. Hodges
In Constant v. Hodges, 292 Ark. 439, 730 S.W.2d 892 (1987), a property owner in the Robinwood subdivision in Little Rock wanted to divide his lot. The subdivision's restrictive covenants contained no express restriction against lot-splitting.
Nevertheless, the Court held that lot-splitting was prohibited based upon the existence of a general plan of development and the language of three relevant instruments. Two of those instruments recited that "only one single family residence...shall be erected."