Statute of Limitations Precluded Collection of Fines

Facts: A homeowner made improvements to his community’s common area that weren’t approved by the association. The homeowner was fined. He later declared bankruptcy. The association filed a “proof of claim” against the homeowner. The homeowner objected to the claim. A California bankruptcy court ruled in favor of the homeowner after it determined that the association’s claim was time barred under the state’s statute of limitations for that type of claim. The association appealed.


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