A few weeks ago, I took two of my girls to New York City for a quick overnight trip to see two Broadway shows. My rule for packing was simple: one backpack each. No rolling bags, no extras. We were walking the city, checking into a hotel, and going straight to the shows. The plain meaning of my instructions were clear: one bag per person.

That’s exactly how the Tennessee Court of Appeals handled a recent case, Killen v. Boardman (Aug. 2025). A landowner tried to build a second house after subdividing her lot. But the subdivision restrictions, recorded in 1971, said:

“Not more than one residence shall be erected on one tract.”

The court enforced the restriction as written. One tract meant one residence. Splitting the lot didn’t erase the covenant or the developer’s plan for the subdivision.

What made the analysis significant was the court’s reliance on the general plan doctrine, which holds that that when developer sells land with restrictions designed to implement a general plan of development, he “impliedly represents to the purchasers that the rest of the land included in the plan is,
or will be, similarly restricted.”

Here, because the subdivision had uniform, long, and narrow tracts designed for farming with one home each, the restrictions were part of a common scheme that applied to all owners. That made the covenant binding, even decades later.

Takeaway for owners and developers: This case is a reminder that restrictive covenants will be enforced according to their plain and ordinary meaning, especially when supported by a general development plan. Creative workarounds like re-subdividing a lot won’t succeed if they conflict with the original scheme. The safest path is to read covenants closely at the start of a project, apply their straightforward meaning, and seek legal advice early rather than risk litigation, injunctions, or even removal of completed work.

Because whether it’s family trips or property law, the rule holds: one backpack means one backpack … and one residence means one residence.