2026-08-08 · Delaware · Courts

Delaware's manufactured home community protections attach to a legal position, not to living somewhere. A resident who is neither the titled owner of the home nor the leaseholder of the lot cannot bring the statute's retaliation or arbitrary-enforcement claims at all.

Buhler v. Winterset Farms, MHC, LLC, C.A. No. 2025-1022-SEM, was dismissed by Senior Magistrate in Chancery Selena E. Molina on January 20, 2026.¹

What the court held on standing

The plaintiff lived in the community but held neither title to the manufactured home nor the lot lease. On that footing the court held he lacked standing to assert:

• 25 Del. C. § 7019 — retaliation by a community owner
• 25 Del. C. § 7018(b) — arbitrary or capricious enforcement of occupancy and use rules
• 42 U.S.C. § 3617 — federal interference, coercion and intimidation

— or to seek a declaratory judgment on any of them, absent well-pleaded facts establishing his own property rights or interests.²

Three further holdings on what does not exist

The court cleared away three theories that recur in Delaware housing disputes.

The Landlord-Tenant Code displaces the common-law claim for quiet enjoyment. A resident cannot plead around the statutory scheme by reaching for the common law.

Delaware recognises no private civil cause of action for harassment.

There is no Delaware tort of “interference with a housing relationship.”

The court also flagged that Chancery was not the right forum in any event, given parallel eviction proceedings.

1. Buhler v. Winterset Farms, MHC, LLC, C.A. No. 2025-1022-SEM, Order Granting Motion to Dismiss (Del. Ch. Jan. 20, 2026) (Molina, Sr. Mag.) ↩
2. 25 Del. C. ch. 70, subch. II — §§ 7013, 7016, 7018, 7019 (lot leases, enforcement, retaliation) ↩
3. 85 Del. Laws c. 206 (Senate Substitute 2 for SB 56), approved September 3, 2025 — manufactured home title transfers and heir protections ↩