In Lamden v. La Jolla Shores Clubdominium Homeowners Assn. (1999) 21 Cal.4th 249, the California Supreme Court adopted for California courts a "rule of judicial deference to community association board decisionmaking" that applies when owners in common interest developments seek to litigate maintenance or repair decisions entrusted to the discretion of their associations' boards of directors. (Id. at pp. 253, 265.) In Lamden, the owner of a unit in a condominium development sued the development's community association for injunctive and declaratory relief, claiming the association's board of directors diminished the value of her unit by deciding to "spot-treat" rather than fumigate her unit to treat a termite infestation. (Id. at pp. 253, 254-256.) Upholding the trial court's judgment in favor of the association, the California Supreme Court held: "Where a duly constituted community association board, upon reasonable investigation, in good faith and with regard for the best interests of the community association and its members, exercises discretion within the scope of its authority under relevant statutes, covenants and restrictions to select among means for discharging an obligation to maintain and repair a development's common areas, courts should defer to the board's authority and presumed expertise." (Id. at p. 252.) Applying this rule to the case before it, the Lamden court concluded the trial court properly deferred to the board's decision to spot-treat the termite infestation rather than fumigate the plaintiff's unit. (Id. at pp. 264-265.) Under the applicable Lamden rule of judicial deference, courts should defer to the authority and presumed expertise of a duly constituted community association board when the board, in discharging an obligation to maintain or repair the development's common areas, makes a discretionary decision that is: (1) within the scope of its authority under relevant statutes, covenants, and restrictions; (2) based upon a reasonable investigation; (3) made in good faith; (4) made with regard for the best interests of the community association and its members. (Lamden, supra, 21 Cal.4th at p. 265.)