From today's FCC Digest:
BRENT BEUMEL, JR., PETITION FOR DECLARATORY RULING. Granted the Petition for Declaratory Ruling. Action by: Deputy Chief, Media Bureau. Adopted: 02/23/2016 by Declaratory Ruling. (DA No. 16-190). MB https://apps.fcc.gov/edocs_public/at...A-16-190A1.doc
The gist of the ruling is that the HOA can not block the petitioner from installing a satellite dish by declaring his "patio" as actually being part of the "common area" and thus not for his exclusive use.