An appellate court in Georgia has held that a quorum is not required for election of the directors of a homeowners’ association when the election is conducted by written ballot as permitted by the association’s bylaws and not at a meeting of the members. It has also held, pursuant to a quirk in homeowners’ association law, that a non-member of the association may not serve as a director, even though the articles of incorporation of the association provide that directors need not be members of the association. The issues arose over contested elections at the Water’s Edge residential real estate community in DeKalb County. The community was built by the developer in 1987 with governing...