A 1st District ruling sets statewide precedent on California’s price-gouging law and clears the way for hundreds of Santa Rosa residents to keep their post-emergency rents intact.
A California appellate court has barred Santa Rosa mobilehome park owners from raising rents to make up for annual increases they couldn’t impose during the multi-year wildfire state of emergency that gripped Sonoma County from 2017 to 2021 — a published ruling that now binds every rent-controlled jurisdiction in the state.
The decision, Western Manufactured Housing Communities Association v. City of Santa Rosa, was certified for publication on April 17 by Division Four of the First District Court of Appeal in San Francisco. It affirms a Sonoma County Superior Court judgment in the City’s favor, and forecloses an interpretation of California’s price-gouging statute that mobilehome park owners had advanced as a workaround to a half-decade of paused rent hikes.
What was at stake
When then-Governor Jerry Brown declared a state of emergency in Sonoma County in October 2017 in response to that fall’s wildfires, he triggered the rent-cap protections of California Penal Code section 396. The statute makes it unlawful to raise housing rents by more than 10 percent during a declared emergency, and — for mobilehome spaces in jurisdictions with rent control — caps the rental price at “the amount authorized under the local rent control ordinance.”
Governors Brown and Newsom kept the emergency in place through December 2021. During that four-plus-year window, Santa Rosa’s mobilehome rent control ordinance — Chapter 6-66 of the City Code — would ordinarily have allowed owners to impose annual CPI-based increases capped at 6 percent. Section 396 blocked them. When the emergency lifted, the owner of the 230-space Rincon Valley Mobilehome Park and the industry trade group Western Manufactured Housing Communities Association sued, arguing that section 396 should now let them “reset” base rents upward to recapture the increases they had been denied — or, alternatively, that the statute had never barred those CPI-based hikes in the first place.
The appellate panel rejected both theories. The ruling Writing for the unanimous panel, Justice Tracie L. Goldman concluded that section 396 fixes the rent ceiling for already-occupied mobilehome spaces at whatever the local ordinance authorized at the moment the emergency was declared — not whatever it would have authorized at any later point during the emergency.
“The policy and purpose of section 396 is, as set forth in its own language, solely and expressly to prevent businesses and landlords from taking advantage of emergency situations to impose ‘excessive and unjustified increases in the prices of essential consumer goods and services,'” the court wrote. As for the post-emergency “reset” theory, the court was equally direct: “Measured against the baseline rent presently charged, the relief Western seeks would increase the rent in an amount precluded by the rent control ordinance.”
The judgment was affirmed in full and the City was awarded its costs on appeal. The panel comprised Presiding Justice Stacey Brown, Justice Goldman, and Marin Superior Court Judge Geoffrey Sweet, sitting by assignment.
Who’s affected
The decision protects current Rincon Valley residents — many of them on fixed incomes — from rent catch-ups that, layered across the four-year emergency, could have exceeded 20 percent. Because the opinion was certified for publication, it now carries precedential weight for every California city and county with mobilehome rent control on the books, including Petaluma, Rohnert Park, and dozens of others.
The court did leave one door open. It noted that Santa Rosa City Code section 6-66.060 provides a “fair return” petition process by which a park owner can seek individualized relief if the rent control regime denies them a reasonable return on their investment. The panel “had no occasion to consider” whether that procedure is the only avenue, leaving room for further litigation on that question.
What’s next
The plaintiffs have 40 days from the April 17 filing — until roughly May 27 — to petition the California Supreme Court for review. They were represented on appeal by Paul J. Beard II of the Pierson Ferdinand firm, a property-rights litigator. The City was represented by Santa Rosa City Attorney Teresa L. Stricker and Assistant City Attorney Nathan L. Putney. Trial Judge Bradford DeMeo presided in the Sonoma County Superior Court below (Case No. SCV-268752). The full opinion is available on the California Courts website under docket A172082.