When the state and HOAs clash, who wins?

Common interest developments (CIDs and HOAs) are fast becoming the dominate housing type within the United States and growth of these self-government models is continuing to raise jurisdictional and legal issues for state lawmakers across the land. The 'social current see' that follows cites a Florida ruling that declared that HOA rules trump state law in a specific area. And now that California government is about to limit HOA restrictions on controlling homeowner choice about landscaping and lawn maintenance, other court rulings are surely coming to sort out future conflicts?