Yee v. City of Escondido

California enacted the Mobilehome Residency Law (MRL), which limited trailer-park owners’ ability to evict their tenants. Typically, a park owner leased space on her property to the owner of a mobile home. Thus the park owner owns the land, the mobile-home owner owns the structure, and the two are landlord and tenant. If the tenant sold the mobile home, the MRL prohibited the landlord from requiring the mobile home, upon its sale, to be removed from his land. The landlord also could not charge a fee for the sale nor refuse to lease to a mobile-home buyer who is able to pay rent for the park space. However, the MRL allowed park owners to evict their tenants if, among other things, the owners wanted to change the use of the land. In 1988, the City of Escondido (defendant) enacted rent control laws that set rent at 1986 levels, which could be increased only if the city council approved. The council would approve any increase that was deemed “fair and reasonable” according to number of nonexclusive, enumerated factors. Yee (plaintiff), a trailer-park owner, challenged the rent control law in San Diego County Superior Court as constituting a taking. Eleven other park owners filed similar suits; all were dismissed. The twelve plaintiffs’ cases were consolidated for appeal. The California Court of Appeal affirmed, holding that the rent law was not a permanent physical taking of the plaintiffs’ property. The trailer-park owners appealed to the California Supreme Court, which denied review. The U.S. Supreme Court granted certiorari.