Woodbridge Condominiums Owners' Association v. Jennings

In Woodbridge Condominiums Owners' Association v. Jennings, 2004 Ohio 5317 (2004), the Court, ruling in favor of the unit owner, held that the condominium rule was subject to 47 CFR 1.4000 and therefore was pre-empted by the federal statute. The Ohio Court determined that it was undisputed that the unit owner had failed to obtain permission of the board of managers, that the patio was part of the limited common area of the condominium complex, and that such actions were a per se violation of the association's rules.