YEE V. CITY OF ESCONDIDO
503 U.S. 519 (1992)
NATURE OF THE CASE: This was a dispute involving a mobile home statute.
FACTS: 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 pad
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.
ISSUE:
RULE OF LAW:
HOLDING AND DECISION:
LEGAL ANALYSIS:
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