Delaware Code

10 Del. C. § 348 (2026)

Disputes involving deed covenants or restrictions

✓ current as of May 2026
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(a) Without limiting the jurisdiction of any court of this State, the Court of Chancery shall, through a Magistrate in Chancery or such other person as may be appointed that Magistrate in Chancery’s designee, mediate disputes involving the enforcement of deed covenants or restrictions when:

(1) An action involving the enforcement of deed covenants or restrictions has been filed with the Court;

(2) At least 1 party is an association or other entity representing the homeowners or lot owners of a subdivision, if such an association or entity exists; and

(3) At least 1 party is a homeowner or lot owner in that subdivision. The mediator shall assist the parties in trying to reach a mutually satisfactory resolution of their dispute. Mediation proceedings under this section are confidential and not of public record.

(b) By rule, the Court of Chancery may further define those types of deed covenant or restriction cases which must be mediated.

(c) Upon the filing of an action involving the enforcement of deed covenants or restrictions, the Court shall schedule a mandatory mediation hearing to be held within 60 days of the filing. If the parties fail to resolve the dispute, the Court shall schedule a trial to be held within 120 days of the failed attempt to mediate the dispute, unless for good cause shown the Court in its discretion concludes that a longer period of time is warranted. A Magistrate in Chancery shall preside over the trial.

(d) The parties to a dispute mediated pursuant to the provisions of this section are not required to be represented by an attorney during a mandatory mediation proceeding.

(e) The nonprevailing party at a trial held pursuant to the provisions of this section must pay the prevailing party’s attorney fees and court costs, unless the court finds that enforcing this subsection would result in an unfair, unreasonable, or harsh outcome.

75 Del. Laws, c. 379, §  170 Del. Laws, c. 186, §  184 Del. Laws, c. 101, § 2
Notes of Decisions
Cited in 37 cases (16 in the last 5 years), 2015–2026 · leading case: Quail Vill. Homeowner's Ass'n, Inc., a Corp. of the State of Delaware v. Janice Rossell (Del. Ch. 2018).
Quail Vill. Homeowner's Ass'n, Inc., a Corp. of the State of Delaware v. Janice Rossell (Del. Ch. 2018). · cites it 8× “(the “Association”), which serves as the association for the homeowners for the Village of Wild Quail Golf and Country Club (“Quail Village”), filed a Verified Complaint to Enforce Deed Restrictions under 10 Del. C. § 348 against Defendant Janice Rossell (“Rossell”), who has…”
Andrea C. Beck v. John A. Greim c/o Bombay Woods Maint. Corp. (Del. Ch. 2018). · cites it 7× “And, I recommend that the Court conclude that the association’s deed restrictions have not been violated under 10 Del. C. §348. This is a final report. I.”
Sheryl Dickerson v. The Villages of Five Points Prop. Owners Ass'n, Inc. (Del. Ch. 2020). · cites it 5× “Second, the association moved to dismiss the complaint alleging that this Court lacks jurisdiction to hear the case under 10 Del. C. §348 since the homeowner sold the property, leaving only a claim for money damages.”
Garnett O'Marrow v. Dean P. Roles, Jr. (Del. Ch. 2016). · cites it 4× “for reimbursement of his reasonable attorney’s fees under the provisions of 10 Del. C. § 348. Defendant Page 1 of 6 took exception to this omission and asked me to modify my Draft Report to award him reasonable attorney’s fees as the successful party in this action based upon…”
Brandywood Civic Ass'n v. Gary Freas (Del. Ch. 2018). · cites it 4× “Background Plaintiff, Brandywood Civic Association (“BCA”), which serves as the association for homeowners in Brandywood, a community of single family homes, filed a Verified Complaint on October 11, 2017 to enforce Brandywood’s Declaration of Restrictions (the “Deed…”
Capano v. Draper Subdivision Ass'n, Inc. (Del. Ch. 2019). · cites it 4× “As mandated by 10 Del. C. § 348, the parties engaged in mediation.”
Keen-wik Associations v. Anthony G. Campisi (Del. Ch. 2020). · cites it 4× “Under the American Rule, each party is normally responsible for their own attorneys’ fees, absent express statutory language to the contrary, a fee-shifting contractual provision, or an equitable doctrine exception, such as the bad faith exception.”
McCaulley Court Maint. Corp. v. Roland L. Davenport, II (Del. Ch. 2018). · cites it 3× “1 In deed restriction cases, 10 Del. C. § 348 provides a 1 Arbitrium (Cayman Is.”
James W. Owen, Jr. v. Tavistock Civic Ass'n, Inc. (Del. Ch. 2019). · cites it 3× “Background The Owens, homeowners in the Tavistock development, filed this case under 10 Del. C. § 348 seeking a judicial declaration that Tavistock improperly enforced a deed restriction in denying the Owens’ request to erect a privacy fence.”
Civic Ass'n of Surrey Park v. Robert Riegel & Erin Riegel (Del. Ch. 2022). · cites it 3× “The parties participated in expedited mandatory mediation under 10 Del. C. § 348, but it was unsuccessful.”
RBY&CC East Side Homeowners Ass'n, Inc. v. Patrick Beebe & Tammy Beebe (Del. Ch. 2023). · cites it 3× “193 After the Association filed the certification required under Court of Chancery Rule 174(c)(2), I found this action eligible to proceed under 10 Del. C. § 348 and referred the Parties to mandatory mediation.”
Stonebridge Townhomes Owners' Ass'n v. Mark T. Ptomey (Del. Ch. 2026). · cites it 3× “”108 For an action to be treated as expedited under Section 348, the Plaintiff needed to “attach to the complaint, a certification that the case is eligible to proceed under 10 Del. C. § 348[,]” as required in Court of Chancery Rule 174(c)(2).”
— 10 Del. C. § 348(a) — 2 cases
McCaulley Court Maint. Corp. v. Roland L. Davenport, II (Del. Ch. 2018). “1 In deed restriction cases, 10 Del. C. § 348 provides a 1 Arbitrium (Cayman Is.”
Quail Vill. Homeowner's Ass'n, Inc., a Corp. of the State of Delaware v. Janice Rossell (Del. Ch. 2018). “(the “Association”), which serves as the association for the homeowners for the Village of Wild Quail Golf and Country Club (“Quail Village”), filed a Verified Complaint to Enforce Deed Restrictions under 10 Del. C. § 348 against Defendant Janice Rossell (“Rossell”), who has…”
— 10 Del. C. § 348(a)(3) — 1 case
Sheryl Dickerson v. The Villages of Five Points Prop. Owners Ass'n, Inc. (Del. Ch. 2020). “Second, the association moved to dismiss the complaint alleging that this Court lacks jurisdiction to hear the case under 10 Del. C. §348 since the homeowner sold the property, leaving only a claim for money damages.”
— 10 Del. C. § 348(c) — 4 cases
— 10 Del. C. § 348(e) — 20 cases
Quail Vill. Homeowner's Ass'n, Inc., a Corp. of the State of Delaware v. Janice Rossell (Del. Ch. 2018). “(the “Association”), which serves as the association for the homeowners for the Village of Wild Quail Golf and Country Club (“Quail Village”), filed a Verified Complaint to Enforce Deed Restrictions under 10 Del. C. § 348 against Defendant Janice Rossell (“Rossell”), who has…”
Capano v. Draper Subdivision Ass'n, Inc. (Del. Ch. 2019). “As mandated by 10 Del. C. § 348, the parties engaged in mediation.”
Keen-wik Associations v. Anthony G. Campisi (Del. Ch. 2020). “Under the American Rule, each party is normally responsible for their own attorneys’ fees, absent express statutory language to the contrary, a fee-shifting contractual provision, or an equitable doctrine exception, such as the bad faith exception.”
James W. Owen, Jr. v. Tavistock Civic Ass'n, Inc. (Del. Ch. 2019). “Background The Owens, homeowners in the Tavistock development, filed this case under 10 Del. C. § 348 seeking a judicial declaration that Tavistock improperly enforced a deed restriction in denying the Owens’ request to erect a privacy fence.”
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