Daily Dicta: Gaudy Christmas Decorations or Religious Discrimination? Jury Slams HOA's Bid to Rein in Extravaganza
The West Hayden Estates homeowners association clearly picked the wrong lawyer to tangle with.
November 27, 2018 at 04:31 PM
10 minute read
A camel is not a “usual or ordinary household pet.”
That's just one of many legitimate-sounding reasons that the West Hayden Estates homeowner's association objected to the Christmas display at the home of Jeremy and Kristy Morris in Hayden, Idaho.
Sure, every town has a few houses where the owners go all-out on Christmas decorations. But the Morris Christmas extravaganza is on another level.
As first reported by the Couer d'Alene/ Post Fall Press, the family uses the event to raise money for two charities that benefit children, which is certainly laudable.
But we're talking a live nativity scene (with the camel), more than 200,000 lights, live music, photos with Santa Claus, portable restrooms and patio heaters, raffle prizes, cotton candy, hot chocolate, people dressed as Roman centurions collecting a “tax” to benefit the charities—and an estimated 6,000 visitors, many of whom arrive via commercial shuttle buses.
The Morris family neighbors in upscale West Hayden Estates—go figure—aren't crazy about all this. And the homeowners association has all sorts of rules that would seem to prohibit such an event, they argued in litigation in federal court in Idaho.
“West Hayden Estates is, and was developed to be, a small, quiet, and private residential subdivision, not a commercial event center. The lights, attractions, noise, in-person attendance, associated traffic, and overall nature of the event render it a violation of the declaration's terms, which plaintiffs agreed to abide by when they purchased their home,” they argued to no avail.
Because clearly, they picked the wrong man to tangle with.
Morris is a lawyer—and not just any lawyer. He got his J.D. from Liberty University School of Law, which says it “exists to equip future leaders in law with a superior legal education in fidelity to the Christian faith expressed through the Holy Scriptures.”
He declined a request for an interview, but according to his LinkedIn profile, he started his legal career as an intern at Liberty Counsel—which has been front-and-center for years in the campaign to “save” Christmas.
“Back in 2003, Liberty Counsel noticed a swell of anti-Christmas sentiment that was threatening to become a tsunami of unconstitutional censorship,” the organization states. “Christmas decorations were packed away or renamed. People wanting to celebrate Christmas were told to sit down and be quiet. Employees, students and even senior citizens were banned from saying certain words!”
The poor West Hayden homeowners association hardly stood a chance.
It didn't matter when the association, which is represented by Smith + Malek in Coeur d'Alene, argued that “The Morrises' Christmas fundraising program attracts large groups of people to a small location, at night, on streets with limited access. Increases in traffic, both pedestrian and vehicular, would restrict emergency access for the community and create an unsafe or hazardous condition.”
(Morris countered that he arranged for off-site parking and shuttle buses.)
Or that under the terms of the HOA, residents are not allowed to post signs or hold commercial events or play music outdoors with loudspeakers.
There's also the rule that “Lighting shall be restrained in design, and excessive brightness shall be avoided.” And the “prohibition against any activity which would in any way interfere with the quiet enjoyment of any owner.” (Like, say, blaring Christmas carols from a house that looks like it belongs on the Vegas Strip and is mobbed by sightseers.)
Also you can't have a camel, not even on a temporary basis.
None of that mattered.
Instead, Morris convinced the jury that the HOA discriminated against him because he's Christian.
Right. Because that's such a problem in Idaho, which is 67 percent Christian, 4 percent non-Christian, 2 percent atheist and 22 percent “nothing in particular,” according to the Pew Research Center.
Not to mention everyone on the West Hayden Estates HOA board is also Christian.
The jury awarded Morris and his wife $75,000—$60,000 in compensatory damages, and $15,000 in punitive damages.
To be sure, the family was helped greatly in their case by the HOA's missteps.
Before the Morris family closed on the house in 2015, they contacted the HOA about their Christmas program.
The association president responded unfavorably, stating in a letter that “we do not wish to become entwined in any expensive litigation to enforce longstanding rules and regulations and fill our neighborhood with the hundreds of people and possible undesirables.” More problematic, the president wrote that “I am somewhat hesitant in bringing up the fact that some of our residents are non-Christians or of another faith and I don't even want to think of the problems that could bring up.”
In a declaration, Kristy Morris described her reaction to the letter, which gives a sense of how the case was litigated.
“I looked up at Jeremy and said, 'I can't believe this they are discriminating us for our faith?!' Jeremy nodded and I then said, 'Let's not do this honey. I don't want to live near people like this.' Jeremy replied, 'Don't let them run us out of where we want to live. '”
In court papers, Morris makes much of the letter, claiming that the HOA was favoring the concerns of non-Christians over Christians.
“Non-Christians or Atheists desire to not have a ministerial program in their neighborhood were given preference over the desire of Christians to spread the gospel on their own property,” Morris and counsel from Fowler St. Clair wrote.
The HOA threatened legal action in 2015 to stop the Christmas display—which it called “offensive to the senses” —but backed down when Morris contacted Fox News, which covered the story along with other national media. (“WAR ON CHRISTMAS!”)
The association shot itself in the foot again when the 2016 incoming president “told Mr. Morris that the HOA's failed attempt to stop the Christmas program through the threat of legal action was not taken on the basis of rule violations, but rather because some members of the association 'don't like Christmas.'”
What!? Don't like Christmas!? It's like that town with the Burgermeister Meisterburger in “Santa Claus is Comin' to Town.” Bah humbug!
The Morris family claimed the HOA enforces its rules selectively, producing photos of a pony at a little girl's birthday party, several houses with Halloween decorations of the “Martha Stewart Living” gourd and scarecrow variety, houses with cute little wooden signs saying things like “Welcome Autumn,” and a lady walking three small dogs when the HOA says you can't have more than two (though it's not entirely clear if all the dogs belonged to her).
“Not one of these actual violations resulted in an attorney threatening to sue these neighbors. In sum, the plaintiffs are members of a protected class and were treated differently,” Morris argued.
Maybe … But mostly, the exhibits show how grossly out-of-sync the Morris family is with the neighborhood aesthetic.
Morris also objected to classifying the event as a commercial use. “[B]y that logic, any Girl Scout fundraiser or lemonade stand could be said to be a commercial use,” he wrote.
Which sounds about right if the lemonade stand attracts 6,000 customers and raises thousands of dollars.
The HOA's motion for a judgment notwithstanding the verdict is due next week, and will put U.S. District Chief Judge B. Lynn Winmill, a Clinton appointee, in an unenviable spot.
Because there's no way to overrule this verdict, as unfounded as it seems, without being cast as Grinch Number 1.
What I'm Reading
A federal judge in Washington, D.C. on Monday tossed a local restaurant's “unfair competition” lawsuit against President Donald Trump and his Pennsylvania Avenue hotel.
“After signing the plea agreement, Manafort committed federal crimes by lying to the Federal Bureau of Investigation and the Special Counsel's Office on a variety of subject matters.”
The complaint asked the court to cancel the companies' certificates of formation using a new provision of Delaware's Limited Liability Company Act, which allows the attorney general to seek the dissolution of LLCs that abuse their “powers, privileges or existence” under state law.
Two Sidley Austin lawyers evaluate what they call guidance that is by “far the most comprehensive in the country” on class action settlements from the Northern District of California.
Apple's lawyer, Daniel Wall, partner at Latham & Watkins, told the justices that although Apple collects a 30 percent commission on each app, the app developers set the price for sale.
No one else has ever been held this long for civil contempt in North Carolina—or just about anywhere else in the country for that matter.
In case you missed it…
On the heels of criminal charges by the Justice Department against two former Goldman Sachs executives, Quinn Emanuel Urquhart & Sullivan's Michael Carlinsky is leading a related civil suit against the investment bank and other defendants.
|This content has been archived. It is available through our partners, LexisNexis® and Bloomberg Law.
To view this content, please continue to their sites.
Not a Lexis Subscriber?
Subscribe Now
Not a Bloomberg Law Subscriber?
Subscribe Now
NOT FOR REPRINT
© 2025 ALM Global, LLC, All Rights Reserved. Request academic re-use from www.copyright.com. All other uses, submit a request to [email protected]. For more information visit Asset & Logo Licensing.
You Might Like
View AllShould It Be Left to the Plaintiffs Bar to Enforce Judicial Privacy Laws?
7 minute readA Reporter and a Mayor: Behind the Scenes During the Eric Adams Indictment News Cycle
Of Predictive Analytics and Robots: A First-Year Federal Judge's Thoughts on AI
Trending Stories
- 1The Fearless Forecaster’s Employment Law Predictions for 2025
- 2Judicial Conference Declines Democratic Request to Refer Justice Thomas to DOJ
- 3People in the News—Jan. 2, 2025—Eastburn and Gray, Klehr Harrison
- 4Deal Watch: Latham, Paul Weiss, Debevoise Land on Year-End Big Deals. Plus, Mixed Messages for 2025 M&A
- 5Bathroom Recording Leads to Lawyer's Disbarment: Disciplinary Roundup
Who Got The Work
Michael G. Bongiorno, Andrew Scott Dulberg and Elizabeth E. Driscoll from Wilmer Cutler Pickering Hale and Dorr have stepped in to represent Symbotic Inc., an A.I.-enabled technology platform that focuses on increasing supply chain efficiency, and other defendants in a pending shareholder derivative lawsuit. The case, filed Oct. 2 in Massachusetts District Court by the Brown Law Firm on behalf of Stephen Austen, accuses certain officers and directors of misleading investors in regard to Symbotic's potential for margin growth by failing to disclose that the company was not equipped to timely deploy its systems or manage expenses through project delays. The case, assigned to U.S. District Judge Nathaniel M. Gorton, is 1:24-cv-12522, Austen v. Cohen et al.
Who Got The Work
Edmund Polubinski and Marie Killmond of Davis Polk & Wardwell have entered appearances for data platform software development company MongoDB and other defendants in a pending shareholder derivative lawsuit. The action, filed Oct. 7 in New York Southern District Court by the Brown Law Firm, accuses the company's directors and/or officers of falsely expressing confidence in the company’s restructuring of its sales incentive plan and downplaying the severity of decreases in its upfront commitments. The case is 1:24-cv-07594, Roy v. Ittycheria et al.
Who Got The Work
Amy O. Bruchs and Kurt F. Ellison of Michael Best & Friedrich have entered appearances for Epic Systems Corp. in a pending employment discrimination lawsuit. The suit was filed Sept. 7 in Wisconsin Western District Court by Levine Eisberner LLC and Siri & Glimstad on behalf of a project manager who claims that he was wrongfully terminated after applying for a religious exemption to the defendant's COVID-19 vaccine mandate. The case, assigned to U.S. Magistrate Judge Anita Marie Boor, is 3:24-cv-00630, Secker, Nathan v. Epic Systems Corporation.
Who Got The Work
David X. Sullivan, Thomas J. Finn and Gregory A. Hall from McCarter & English have entered appearances for Sunrun Installation Services in a pending civil rights lawsuit. The complaint was filed Sept. 4 in Connecticut District Court by attorney Robert M. Berke on behalf of former employee George Edward Steins, who was arrested and charged with employing an unregistered home improvement salesperson. The complaint alleges that had Sunrun informed the Connecticut Department of Consumer Protection that the plaintiff's employment had ended in 2017 and that he no longer held Sunrun's home improvement contractor license, he would not have been hit with charges, which were dismissed in May 2024. The case, assigned to U.S. District Judge Jeffrey A. Meyer, is 3:24-cv-01423, Steins v. Sunrun, Inc. et al.
Who Got The Work
Greenberg Traurig shareholder Joshua L. Raskin has entered an appearance for boohoo.com UK Ltd. in a pending patent infringement lawsuit. The suit, filed Sept. 3 in Texas Eastern District Court by Rozier Hardt McDonough on behalf of Alto Dynamics, asserts five patents related to an online shopping platform. The case, assigned to U.S. District Judge Rodney Gilstrap, is 2:24-cv-00719, Alto Dynamics, LLC v. boohoo.com UK Limited.
Featured Firms
Law Offices of Gary Martin Hays & Associates, P.C.
(470) 294-1674
Law Offices of Mark E. Salomone
(857) 444-6468
Smith & Hassler
(713) 739-1250