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This approach recognizes the discretion of the majority of unit owners while at the same time limiting their rule-making authority to those matters that are reasonably related to the promotion of the health, happiness and peace of mind of the unit owners.[iv] If a rule reasonably restricts an activity, such as smoking, because of serious concerns such as the effects of heavy smoking in units on neighboring unit owners courts will not invalidate the rule because it also incidentally restricts less harmful behavior such as the unit owner who smokes just one cigarette a month.[v] If a restriction affects an owner who purchased the unit before the restriction went into place, courts have articulated a slightly more stringent standard

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