Donovan Smith HOA v. Donovan Smith MHP, LLC

Summary

The Supreme Court affirmed the arbitrator's above-inflation rent increase because the record supported a rational inference that improvements increased the landowner's costs and because comparable-community rents supported the market-rent factor. The Court held that its affirmance was limited to the record presented, where the homeowners had not timely sought the landowner's underlying financial records or argued that those records were required. The Court rejected the Superior Court's broader suggestion that a landowner need not produce relevant business records, while recognizing that legitimate confidentiality concerns may be addressed through protective conditions.