California Legal Brief

The Rule of Western Manufactured Housing Communities Association v. City of Santa Rosa is that during a declared state of emergency, Penal Code section 396's definition of "rental price" for rent-controlled mobilehome spaces occupied at the time of the emergency declaration refers to the rental amount authorized under the local rent control ordinance at the time of the emergency declaration, not at any given time thereafter, and mobilehome park owners cannot "recoup" suppressed rent increases by using those increases as a baseline for post-emergency rent calculations, under circumstances where rent-controlled mobilehome spaces are subject to both local rent control ordinances and section 396's 10-percent cumulative cap during a multi-year emergency declaration.