Narrative Opinion Summary
The appellants, owners of mobile home parks, challenged a Santa Cruz County rent control ordinance enacted in 1982, citing the potential for takings without just compensation under the Fifth and Fourteenth Amendments. Their challenge was influenced by a precedent set in Hall v. City of Santa Barbara, which raised similar issues. The district court dismissed the appellants’ suit based on the statute of limitations, determining that the cause of action accrued with the ordinance's initial enactment in 1982. The court applied the statute of limitations for § 1983 claims, reduced to one year by Wilson v. Garcia, and found the complaint filed in 1987 untimely. The appellants argued that their injury arose with each mobile home sale and that the 1987 amendment, which removed a sunset provision, constituted a new cause of action. The court rejected these arguments, finding that the ordinance's provisions had consistently affected the appellants' property interests since 1982. The court also noted that the potential for ordinance repeal did not negate the existence of a taking claim. Ultimately, the dismissal was affirmed, and the court declined to address the ripeness of the claims or state remedies.
Legal Issues Addressed
Accrual of Cause of Actionsubscribe to see similar legal issues
Application: The court held that the cause of action accrued at the time the ordinance was enacted in 1982, rejecting the argument that a new cause of action arose with each mobile home sale or the 1987 amendment.
Reasoning: The court emphasized that the key question was whether the cause of action accrued with the ordinance's enactment in 1982. The appellants argue that their injury arises from the sale of mobile homes rather than the ordinance itself, claiming a new cause of action arises with each sale. This argument is rejected.
Impact of Ordinance Reenactment on Legal Claimssubscribe to see similar legal issues
Application: The reenactment of the ordinance without a sunset provision did not alter the accrual of the cause of action or create a new claim.
Reasoning: While the district court recognized that reenactment could alter damages, it clarified that this does not influence the accrual of a cause of action.
Statute of Limitations for § 1983 Claimssubscribe to see similar legal issues
Application: The court determined that the statute of limitations for § 1983 claims in California is one year following the Wilson v. Garcia decision, and De Anza's complaint was filed outside this period.
Reasoning: Under Wilson v. Garcia, the statute of limitations for § 1983 claims in California is now one year, reduced from three years. The court noted that De Anza's complaint, filed on January 22, 1987, was outside both the three-year limit from the ordinance enactment and the one-year limit following Wilson, which expired on April 17, 1986.
Takings Claim under Rent Control Ordinancesubscribe to see similar legal issues
Application: The court found that the rent control ordinance did not create a new cause of action with its 1987 amendment, as the challenged provision remained unchanged since 1982.
Reasoning: The appellants’ theory posits that the original enactment represented a 'temporary' taking, with subsequent claims for a 'permanent' taking. However, the ordinance's challenged provision has remained unchanged since 1982, leading to similar injuries in both years.