Western Manufactured Housing Cmty. Assn. v. City of Santa Rosa

── Western Manufactured Housing Cmty. Assn. v. City of Santa Rosa ── Court: California Court of Appeal Date: April 17, 2026 Category: General Filed 4/17/26 CERTIFIED FOR PUBLICATION IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA FIRST APPELLATE DISTRICT DIVISION FOUR Western Manufactured Housing Communities Association et al., A172082 Plaintiffs and Appellants, v. (Sonoma County Super. City of Santa Rosa et al., Ct. No. SCV-268752) Defendants and Respondents. Plaintiffs Western Manufactured Housing Communities Association, a nonprofit organization that promotes the interests of owners, operators, and developers of manufactured home communities in California, and Rincon Valley Mobilehome Park (Rincon; collectively Western or plaintiffs) appeal a judgment entered in favor of defendants City of Santa Rosa, the Department of Housing and Community Services of the City of Santa Rosa, and Megan Basinger, as interim director of the named department (collectively the City) on plaintiffs’ complaint for declaratory and injunctive relief and petition for writ of mandate. Rincon owns and operates a 230-space mobilehome park in Santa Rosa. The case arises out of a wildfire state of emergency in Sonoma County that lasted for several years. Penal Code section 396 (section 396) prohibits an increase in the rental price of a mobilehome space of more than 10 percent during a declared state of emergency. (Id., subd. (e).) For mobilehome spaces subject to a local rent control ordinance and already rented at the time of the 1 declaration, the statute defines “rental price” as “the amount authorized under the local rent control ordinance.” (Id., subd. (j)(11)(D).) Disputing the City’s position that this definition refers to the amount authorized under the local ordinance at the time of the declaration of emergency, Western contends that it refers instead to the amount authorized under the local ordinance at any given time. Under Western’s interpretation, mobilehome park owners may impose annual rent increases consistent with Santa Rosa’s ordinance, without regard to the cumulative 10-percent cap in section 396, because at any given time they are charging a rental price authorized by the ordinance. In the alternative, Western contends that, once the state of emergency ended, owners were entitled to impose new rents calculated from a baseline that assumed the annual increases authorized by the local ordinance, but prohibited by section 396, had been imposed. We conclude the trial court properly rejected both arguments, although some of our reasoning is different. BACKGROUND I. Subdivision (a) of section 396 reads: “The Legislature hereby finds that during a state of emergency or local emergency, including, but not limited to, an earthquake, flood, fire, riot, storm, drought, plant or animal infestation or disease, pandemic or epidemic disease outbreak, or other natural or manmade disaster, some merchants have taken unfair advantage of consumers by greatly increasing prices for essential consumer goods and services. While the pricing of consumer goods and services is generally best left to the marketplace under ordinary conditions, when a declared state of emergency or local emergency results in abnormal disruptions of the market, the public interest requires that excessive and unjustified increases in the 2 prices of essential consumer goods and services be prohibited. It is the intent of the Legislature in enacting this act to protect citizens from excessive and unjustified increases in the prices charged during or shortly after a declared state of emergency or local emergency for goods and services that are vital and necessary for the health, safety, and welfare of consumers, whether those goods and services are offered or sold in pe