In Walters v. Colford, 900 N.W.2d 183 (Neb. 2017), a developer sold 14 lots with identical covenants restricting the property to one single-family two-story house and garage. The developer then solder a five-acre adjacent parcel without the covenants. The Nebraska Supreme Court held that the five-acre parcel was not part of the original common scheme and was not impliedly limited by the covenants. There was no basis for putting the future owners of that neighboring parcel on notice that they were part of a common scheme. Developers can avoid litigation about this issue by filing a declaration with a map that explicitly identifies the properties intended to be mutually restricted.