Yee v. City Of Escondido

503 U.S. 519 (1992)


In 1978, California enacted a Mobile Home Residency Law because of the inherent nature of mobile homes in that they are not really mobile. The law protected mobile home owners from actual or constructive eviction. Various communities within California adopted mobile home rent control ordinances, and Escondido (D) did so in 1988. D's ordinance set rents back to the 1986 levels, and rent increases were prohibited without the approval of the City Council based on eleven different factors. Yee (P) filed suit against the ordinance claiming that the rent control ordinance deprived P of all use and occupancy as the ordinance granted the tenants the right to permanently occupy and use P's property. P sought six million in damages and a declaration that the rent control ordinance is unconstitutional and an injunction barring its enforcement. P claims that any reduction in the rent of pads results in a corresponding increase in the value of a mobile home and because under the State Law a park owner may not evict or easily convert the property to other uses, the mobile home owner is effectively a permanent tenant with a right to occupy the land indefinitely at sub-market rates and a right to transfer that interest.