Bon Ayre Land, LLC, Appellee Below-Appellant v. Bon Ayre Community Association, Appellant Below-Appellee

Summary

The Court affirmed the Superior Court’s determination that a manufactured-home community owner seeking a rent increase above CPI-U must prove both a direct relationship to operating, maintaining, or improving the community and justification under at least one statutory factor. The Court also held that market rent may be established through any relevant and reliable evidence permitted by the Act, not only actual lease terms from comparable communities. Justice Vaughn, dissenting, would have permitted market-rent evidence to establish the required relationship and remanded for further review of the arbitrator’s decision.