In September of 2013, in Hawk v. PC Village Association, the Court of Appeals upheld an order from the trial court in favor of the homeowner who wanted to post a “For Sale” sign on his property.  The association had twice removed signs he had installed, so he sued to enjoin the association from removing his sign.  Mr. Hawk relied on two relatively new statutes, ARS 33-1808 and ARS 33-441 which expressly prohibit associations from barring homeowners from erecting for sale signs.  The association argued that because the statutes went into effect after the CC&Rs, that the statutes impaired existing contractual rights banning any signs in yards, and were, therefore, unconstitutional.  The Court of Appeals rejected that argument, in part, because the CC&Rs themselves contained an exception for signs whose prohibition was barred by law.  To the Court of Appeals, this meant that the contractual rights were seen as flexible and subject to change over time and thus applying the two statutes at issue in the case was not a substantial impairment of the contractual rights.  The Court of Appeals did not undertake further constitutional analysis, presumably saving that for a set of CC&Rs which does not contain any exceptions to a ban on signs.