Down the (Cross)hatch

Willowgate Homeowners Ass’n v. Young rejected a HOA’s argument that the “crosshatched area” on a map was sufficient under the Statute of Frauds to describe an alleged common area. Specifically:

• Unlike the area in the map around a lake (with a description saying that “[a]ll areas except those crosshatched is common ground”), the designations for the private lots—including the lot at issue—did not use this clarifying language.
• Adding to the uncertainty, nothing in the record explained what the marks around that lot on the map were intended to mean—including crosshatched and non-crosshatched areas, as well as lines or arrows pointing to certain sections.
• Moreover, the map lacked a measurement scale, fixed markers, or other such data about the dimensions or boundaries of the crosshatched, non-crosshatched, lined, or arrowed areas.

No. 05-24-00173-CV, Apr. 21, 2025 (mem. op.).