DeNina v. Bammell Forest Civic Club, Inc
In DeNina v. Bammell Forest Civic Club, Inc., 712 S.W.2d 195, 198 (Tex. App.--Houston 14th Dist. 1987, no writ), the appellate court examined whether a thirteen-foot diameter satellite disc and its poured-cement base violated a provision of a deed restriction which provided that all subdivision lots must be used for residential purposes and that no structure could be built or placed on the lot other than a single-family home and a garage. Id. at 198.
The DeNina court held that the satellite disc was not a structure because it was not a multi-family residence, and the purpose of the particular deed restriction was to limit residences within the subdivision to single-family residences. Id.