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.”