Depending on the governing documents or state law, the HOA may have the authority to place liens on a property (for non-payment of assessments and/or noncompliance with CC&Rs, an example would be the costs to remove a noncompliant structure such as a mobile home on a lot restricted to "site built" housing) and to, ultimately, foreclose on it. Homeowners have the ability to defend against such actions, and are usually entitled to sue HOA's for contractual or statutory violations, or for a legal determination as to the enforceability of a provision in the governing documents. However, because HOA's are private associations, they are not considered "state actors" subject to constitutional constraints, and therefore homeowners cannot sue for civil rights violations under 42 U.S.C. 1983.