merriam-webster defines a garden apartment in american english as "a multiple-unit low-rise dwelling having considerable lawn or garden space" the apartment buildings are often arranged around courtyards that are open at one end. such a garden apartment shares some characteristics of a townhouse: each apartment has its own building entrance, or shares that entrance via a staircase and lobby that adjoins other units immediately above and/or below it. unlike a townhouse, each apartment occupies only one level. such garden apartment buildings are almost never more than three stories high, since they typically lack elevators. however, the first "garden apartment" buildings in new york, usa, built in the early 1900s, were constructed five stories high. some garden apartment buildings place a one-car garage under each apartment. the interior grounds are often landscaped.