California Appellate Court (January 13, 2014) ruled that the legislative intent behind Civil Code 1367.1 allows for partial payments to pay down delinquent assessments, and limits the remedy of foreclosure to only a last resort. Accordingly, the Associations refusal of the partial payments by the owners did not justify a foreclosure.

See: Huntington Continental Town House Association , Inc. v. The JM Trust et al.