Can a homeowner's association bring an enforcement action against a property owner who is not a party to the land covenant?

California confirmation of this concept is found in Russell v. Palos Verdes Properties (1963) 218 Cal.App.2d 754, 32 Cal.Rptr. 488. It was there held that a homeowners' association granted enforcement rights by the development's declaration of land restrictions had standing to bring an enforcement action, notwithstanding that it owned no realty in the covenant area. The court found that the land covenant caused the association to become a [215 Cal.App.3d 1148] beneficiary of rights granted to all landowners, and thereby to have an equitable interest in the land sufficient to justify its enforcement action. ³