United States Supreme Court Upholds Ordinance Mandating Rents Ceiling on Mobile Homes

States Supreme Court held that an ordinance mandating a ceiling on rents mobile home park owners can charge does not constitute a Fifth Amendment taking by the government and, therefore, does not entitle the park owners to compensation. Background In 1978, the State of Califoniia enacted the Mobilehome Residency Law, which limits a mobile home park owner's ability to terminate the tenancy of a mobile home owner. Valid reasons for termination include: the nonpayment of rent, the mobile home owner's violation of law or park rules, and the park owner's desire to change the use of his land. The law also provides that when a mobile home is sold, the park owner may not disapprove of the purchaser if the purchaser has the ability to pay rent. The law was enacted upon a legislative finding that mobile home owners needed unique protection from actual or constructive eviction because of the high cost of moving mobile homes, the potential for damage resulting from moving them, the requirements relating to the installation of mobile homes, and the cost of landscaping or lot preparation. In 1986, the city of Escondido, California adopted a mobile home rent control ordinance. This ordinance set rents according to their 1986 levels and prohibited rent increases without the approval of the Escondido City Council. John and Irene Yee ("the Yees") own two mobile home parks in the city of Escondido. A few months after the adoption of the rent control ordinance, the Yees filed suit in San Diego County Superior