Anaheim Mobile Estates v. State of Cal.
G063421M
| Cal. Ct. App. | Aug 14, 2025Background
- Anaheim Mobile Estates, LLC (AME) operates a mobilehome park crossing two cities in Orange County, California.
- Civil Code section 798.30.5, effective 2022, caps annual rent increases in such parks at 3% plus CPI or 5%, whichever is lower.
- AME challenged the statute as facially unconstitutional, arguing the absence of a 'fair return rent adjustment mechanism' denies due process.
- The State of California denied all allegations, including AME’s standing, and asserted the law is not unconstitutional.
- The trial court granted AME judgment on the pleadings, finding the statute unconstitutional due to lack of procedural safeguards; the State appealed.
- On appeal, the court reversed, rejecting both AME's constitutional challenge and the trial court's view that an adjustment mechanism is always necessary; it also noted standing was at issue due to the State’s general denial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is Section 798.30.5 unconstitutional without a fair return adjustment mechanism? | Lack of mechanism renders statute facially invalid; fair return required by case law | Not required; statute not confiscatory in all/most cases; precedent misread | Not unconstitutional on its face without such a mechanism |
| Does AME have standing to bring the challenge? | Standing presumed on face of complaint | General denial puts standing at issue | Standing was contested; judgment on pleadings was improper |
| Is a procedural fair return remedy constitutionally required in all rent control laws? | California Supreme Court requires mechanism in all cases | Only required if statute would otherwise be confiscatory | Mechanism is required only to avoid actual or likely confiscatory results |
| Can judgment on the pleadings be granted when answer denies essential facts? | Legal question only; answer's denial is irrelevant | Denial raises material factual issues | Judgment on pleadings improper where answer puts facts at issue |
Key Cases Cited
- Birkenfeld v. City of Berkeley, 17 Cal.3d 129 (Cal. 1976) (requires opportunity for adjustment in case of confiscatory rent control, not blanket requirement)
- Calfarm Ins. Co. v. Deukmejian, 48 Cal.3d 805 (Cal. 1989) (rate adjustment not always mandatory; scrutinize if law is confiscatory)
- Kavanau v. Santa Monica Rent Control Bd., 16 Cal.4th 761 (Cal. 1997) (fair return process supports constitutionality but not always required)
- Galland v. City of Clovis, 24 Cal.4th 1003 (Cal. 2001) (constitutional if rent control allows timely adjustment to avoid regulatory lags)