HomeMy WebLinkAboutCM Renter Protections____________________________________________________________________________________
FOR CITY CLERK ONLY
Council Meeting: 02/04/2019
Disposition: Accepted report and provided direction to staff
Agenda Item No: 7.a
Meeting Date: February 4, 2019
SAN RAFAEL CITY COUNCIL AGENDA REPORT
Department: City Manager’s Office
Prepared by: Andrew Hening,
Director of Homeless
Planning & Outreach
City Manager Approval: ______________
TOPIC: RENTER PROTECTIONS
SUBJECT: PROPOSED RENTER PROTECTION POLICIES – MANDATORY MEDIATION AND
JUST CAUSE EVICTION
RECOMMENDATION: Accept Informational Report and Provide Direction to Staff.
BACKGROUND:
In fall 2016, the County of Marin started exploring a variety of policies and programs that could address
ongoing challenges with discrimination, affordability, and substandard living conditions in Unincorporated
Marin’s rental housing stock. Unlike the cities and towns in Marin County, the County – through its
Community Development Agency – has full-time staff working on housing issues. As a result, many local
cities and towns have looked to the County for leadership in this policy area. To-date, the County has
adopted the following renter protection measures:
-Source of Income Discrimination (San Rafael has also adopted)
-Mandatory Mediation
-Just Cause Eviction
-Business License Data Collection
The City Council’s Goals and Strategies for Fiscal Year 2018-19 include goals around facilitating
affordable housing. For example, one strategy is to “Explore protections to increase rental and ownership
housing affordability.” On August 20, 2018, the Community Development Director provided the City
Council with a “Housing Update” report. The City Council provided direction to work on a number of items
for future Council consideration. One of these items was as Source of Income Discrimination Ordinance,
which the Council considered and approved at the end of 2018. Staff was also directed to return with
information regarding proposed ordinances for Mandatory Mediation and Just Cause evictions.
SAN RAFAEL CITY COUNCIL AGENDA REPORT / Page: 2
San Rafael’s Ownership & Rental Markets
In every community there are two housing markets. At the most fundamental level, there is the ownership
market for the housing stock itself. According to the City of San Rafael’s 2015-2023 Housing Element, in
2010 San Rafael had 24,011 housing units, which was comprised of 56% single family units, 42%
multifamily units, and 2% mobile homes and other units.
The second market is layered on top of the first; it is the rental housing market. This market results from
the fact that among the overall housing stock, every community has its own unique mix of owner-occupied
units and for-rent units. According to the 2010 US Census, renter households occupied 48% of San
Rafael’s housing units, and owners occupied 52% of housing units.
Over the last ten years, both markets have been impacted by a slowdown in housing creation. 80% of
San Rafael’s housing stock was built before 1980. Between 1990 and 2000, San Rafael experienced a
9% growth in housing stock. Growth has further slowed since that time.
Even as housing stock growth has slowed, demand for housing has persisted and increased. In 2013,
the Association of Bay Area Governments, which sets regional growth targets through the Regional
Housing Needs Allocation (RHNA), forecasted a 5% growth in households in San Rafael for each decade
from 2010 to 2040. This growth rate means that San Rafael’s 57,700 residents in 2010 will increase to
68,700 by 2040.
If the rate of new housing creation is lower than the rate of population growth, then supply and demand
will continue to diverge, and housing prices – in both the ownership and rental markets – will continue to
rise. With that being said, the “consumers” in each market experience these price increases differently.
For existing owners, higher prices mean increased equity. By comparison, renters experience increasing
prices as just that, higher prices. The County of Marin’s Community Development Agency shared the
following infographic at their September 11, 2018 “Preventing Displacement: Rental Housing Workshop.”
Figure 1 – Home Equity vs. Rental Prices in Marin County, 2009-2017
SAN RAFAEL CITY COUNCIL AGENDA REPORT / Page: 3
This dynamic reveals a crucially important link between the ownership market and the rental market. If
more and more of a household’s income is directed towards increasingly expensive rents, while at the
same time the cost of becoming an owner also continues to rise (e.g. the cost of a down payment will
continue to rise as prices rise), it becomes increasingly difficult for renters to become owners.
The Challenges for Renters
In discussing “the housing market,” it is easy to conflate the ownership market and the rental market.
These two markets are of course interrelated in significant ways, such as the overall consumer demand
for housing and the overall supply of housing units. At the same time, each market is shaped by unique
policies and challenges. The ownership market, for example, is impacted by construction costs, local
zoning, and state regulations (e.g. the California Environmental Quality Act). The rental market, by
comparison, is shaped by eviction laws, leasing requirements, and other tenant and landlord protections.
There are a variety of challenges to creating more supply in the ownership market. As a follow up to the
San Rafael Community Development Director’s August 20, 2018 “Housing Update” Report, in 2019
Community Development staff will be returning to Council to discuss local “Barriers to Housing Creation.”
Additionally, there are a variety of new state laws and funding mechanisms that have been recently
adopted or that are currently under consideration in the Legislature, which could also significantly impact
the overall housing stock in San Rafael. W hether these changes are occurring at the local or state level,
any impact to the housing supply will occur on a medium to long-term time horizon. In the meantime,
aside from simply being unable to become owners, there will continue to be urgent challenges for renters
in our community.
➢ Housing Overpayment – Housing overpayment, as defined by the state and federal government,
refers to spending more than 30% of income on housing. According to a 2018 report from the
Marin Economic Forum, the majority of low-income renters in Marin County fall within this
definition of housing overpayment (Figure 2).
Figure 2 – Rent Burden by Income Group
SAN RAFAEL CITY COUNCIL AGENDA REPORT / Page: 4
➢ Low Vacancy Rates – The vacancy rate refers to the number of available housing units – for
sale or rent – available at any given point in time. According to the City of San Rafael’s Housing
Element, “A low vacancy rate may indicate that households are having difficulty in finding housing
that is affordable, leading to housing overpayment and/or overcrowding.” Additionally, in rental
markets with low vacancy rates, tenants without viable housing alternatives might end up
choosing to reside in rental units with deficiencies that affect the habitability of the property. The
City of San Rafael does have a Housing Inspection Program to get such deficiencies corrected.
According to the Marin County Community Development Agency, the rental vacancy rate in Marin
County is currently below 3%. A healthy rate is closer to 6 to 7%.
➢ Jobs / Housing Imbalance – According to the San Rafael Housing Element, more than 87% of
those employed in San Rafael reside in other cities, which implies a significant jobs / housing
imbalance. Affordable workforce housing is needed for those who contribute vital services to the
City but whose incomes limit their ability to obtain affordable housing in San Rafael. Examples of
workforce occupations priced out of the local housing market include nursing assistants,
elementary and high school teachers, and many public employees.
➢ Homelessness – According to Marin County’s 2017 Homeless Point-in-Time-Count, the leading
reason people cited for becoming homeless was “economic issues” (42%). According to the same
study, currently homeless persons cited the top three forms of assistance needed for exiting
homelessness as housing-related: rental assistance (62%), more affordable housing (60%), and
money for moving costs (46%). In 2018, fully 100% of the people who have been placed in
housing through the Marin County Continuum of Care moved into a rental arrangement, not an
ownership arrangement.
ANALYSIS:
Over the last two years the County of Marin has explored and adopted a variety of renter protection
measures to address the dilemmas outlined above. A summary of these measures is provided below.
Mandatory Mediation
Mediation is a process in which a neutral third party facilitates the negotiation of a mutually acceptable
resolution to a dispute between parties. Mediation programs commonly apply voluntary, private and
informal processes.
Some jurisdictions have used the mediation concept to help renters. With “Mandatory” Mediation, if a
triggering event occurs (e.g. rent is increased by a certain percentage), then the tenant is able to request
mediation services. It is then mandatory that the landlord participates in the mediation process, but the
parties cannot be compelled to reach a resolution. Instead, the goal of these programs is to facilitate
constructive conversations in a neutral and accountable environment.
The County of Marin has joined a variety of other Bay Area communities in adopting mediation policies
to assist renters:
SAN RAFAEL CITY COUNCIL AGENDA REPORT / Page: 5
Figure 3 – Bay Area Rental Mediation Programs
Jurisdiction
Palo Alto Concord Union City County of Marin
Program “Mandatory
Response Program”
“Residential Rent
Review Program”
“Rent Review” “Rental Housing
Dispute
Resolution”
Date of Adoption December 2001
July 2017 June 2017 December 2017
Parties that Can
Initiate
Tenants, owners,
property managers
Tenants Tenants Tenants, landlords
Reasons to Initiate
Rent increases,
repairs,
maintenance,
deposits
10% rent increase
in a 12-month
period
7% rent increase in
a 12-month period
5% rent increase in
a 12-month period
Applicability
Applies to landlords
with two or more
rental units
Applies to all
Concord rental
properties with 3 or
more units
Applies to all rental
units including
single family
homes / condos;
there is an
exception for any
unit subject to a
regulatory
agreement (e.g.
Section 8,
government owned
and operated)
Applies to all rental
units including
single family
homes / condos;
there is an
exception for any
unit subject to a
regulatory
agreement (e.g.
Section 8,
government owned
and operated)
Participation
Voluntary Mandatory Mandatory Mandatory
Administration /
Enforcement
Palo Alto Mediation
Program
ECHO Housing ECHO Housing District Attorney
Consumer
Protection Unit
Cost to Participants No cost
No Information
Available
No Information
Available
No cost
Figure 3 highlights the diversity of policy questions that can shape Mandatory Mediation programs. Some
of those questions include:
➢ When Does Mandatory Mediation Apply?
Mandatory Mediation can be tailored to address rapid increases in rental housing costs by
requiring mediation for rental increases over a specified threshold (e.g. increases of more than
five percent (5%) over a twelve-month period could be subject to Mandatory Mediation). In the
alternative, Mandatory Mediation can be triggered by any rent increase, or by request from either
a landlord or tenant for capital expenses or improvements (e.g. if a landlord replaces the roof and
passes the cost through to the tenant, or if a tenant wants to permanently install new laundry
facilities).
SAN RAFAEL CITY COUNCIL AGENDA REPORT / Page: 6
➢ What issues are subject to Mandatory Mediation?
In addition to rent increases, a Mandatory Mediation program can facilitate the constructive
resolution of disputes involving “services reductions,” which result when a reduction in the level
or amount of tenant benefits or privileges occur without an accompanying fair and corresponding
decrease in rent. Examples of common service reductions include the cutback of parking
privileges, maintenance or repairs, utilities, or elevator service.
➢ Are the results of Mandatory Mediation binding?
If the parties involved come to an agreement, a settlement agreement can be prepared that will
bind the parties. However, the parties may not come to an agreement and then there is no
“resolution” to comply with. The mediator will not make a decision for the parties unless the parties
have specifically agreed to such a process.
➢ Are anti-retaliation provisions desired?
Many jurisdictions add anti-retaliation policies to encourage the use of mediation services and
prohibit activities that could circumvent the mediation process.
The County of Marin passed Mandatory Mediation legislation in December of 2017, and the law went
into effect at the beginning of 2018. Since enacting this legislation, the County of Marin District Attorney
Office’s Consumer Protection Unit has mediated 12 cases. On average, there has been one case
mediated per month. The outcomes of these cases have been highly variable. For example, in one
case the proposed rent increase did not change, but the landlord agreed to a two-year lease. In another
example the landlord agreed to rehabbing part of the unit, but the increase stayed in place. In some
cases, there were simply no changes.
February 2018: 1 case Ineligible
March 2018: 3 cases 2 Ineligible, 1 Eligible: mediation conducted, agreement reached
April 2018 – 1 case Eligible: mediation conducted, no agreement reached.
May 2018 – 1 case Eligible: mediation conducted, no agreement reached.
June 2018 – 1 case Eligible: agreement reached.
July 2018 – 1 case Ineligible
August 2018 – 2 cases 1 Ineligible, 1 Eligible: mediation conducted, agreement reached.
September 2018: None
October 2018: 1 case Ineligible
November 2018: None
December 2018: 1 case Eligible: mediation conducted, agreement reached.
County staff believed the relatively low utilization could be occurring for two reasons. On one hand, the
low utilization could be explained by the fact that the ordinance was actually working. Citing the “black
robe” effect, for many landlords, simply receiving a notice about these new regulations was enough to
limit significant recent increases. On the other hand, staff was hearing from renters that price increases
were still happening, but tenants were afraid to request mediation services because there was no
guarantee that the landlord wouldn’t just evict them after requesting the service. In response to this latter
perceived cause, County staff began working with the Board of Supervisors on an additional policy that
could alleviate some of that concern.
SAN RAFAEL CITY COUNCIL AGENDA REPORT / Page: 7
Just Cause Eviction
Under California law, landlords have the legal right to terminate a periodic tenancy without reason so
long as they furnish the tenant proper written notice of termination. For a written notice of termination to
be legally sufficient under State law, a residential tenant living in a home for less than one year must be
provided with at least 30-days’ written notice; the termination of a tenancy where the tenant has resided
in a home for one year or more must be noticed at least 60 days in advance. Landlords can also serve
tenants with a three-day written eviction notice for any cause consistent with the California Code of Civil
Procedure §1161, such as non-payment of rent or violation of a covenant in the lease. In addition, the
Ellis Act allows Californians to withdraw their property from the residential rental market.
Just Cause policies are intended to provide stability for households who rent by regulating the grounds
for eviction, typically by prohibiting termination of a residential tenancy without expressly stating the
reason. These policies serve to promote greater awareness of the rights and responsibilities of landlords
and tenants and provide a clear and transparent process for evictions and lease terminations, particularly
when rental agreements do not exist or lack specificity.
Just Cause ordinances have existed in California and the Bay Area since the late 1970s and have recently
reemerged as a tool to provide security and stability for households that rent by preventing the termination
of residential leases without specific, pre-defined justification. Just Cause ordinances typically identify
acceptable reasons that a landlord may terminate a tenancy “for cause” (e.g. failure to pay rent, nuisance
behavior), as well as other reasons a landlord could evict for “no cause” (e.g. the landlord is moving back
into the unit). Just Cause ordinances fully retain the rights of landlords to terminate a lease for valid
reasons, but they also help prevent evictions of responsible tenants, providing them with greater security
and stability.
As with Mandatory Mediation policies, there are limits to what Just Cause policies can achieve. Without
rent stabilization policies, Just Cause ordinances do not prevent landlords from raising rents. As a result,
Just Cause ordinances alone generally do not protect tenants from displacement caused by a landlord
raising the rent to an unaffordable level – a process that could be called “economic eviction.” Furthermore,
the Ellis Act (California Government Code sections 7060 through 7060.7) places limitations on both the
ability of local governments to require a landlord to continue to rent units as well as tenant protections. A
landlord is always entitled to permanently remove a rental unit from the housing market, but a Just Cause
ordinance can provide a tenant with a right to return to the unit if the property owner decides to rent it
again in the future, although potentially at an increased rental amount.
The County of Marin has joined a variety of other Bay Area communities in adopting Just Cause policies
to assist renters. Of note, in January of 2019, the Association of Bay Area Governments adopted a 10-
point action plan designed to alleviate the housing crisis in the Bay Area. The “CASA Compact” includes
Just Cause as one of the prescribed policies.
Figure 4 – Just Cause Policies in California
Jurisdiction
Emeryville Union City San Diego County of Marin
Program “Eviction
Harassment
Ordinance”
“Residential
Landlord and
Tenant relations
Ordinance”
“Tenants’ Right
to Know
Regulations”
“Just Cause for
Evictions”
Date of Adoption December 2016 April 2017 March 2004 December 2018
SAN RAFAEL CITY COUNCIL AGENDA REPORT / Page: 8
Applicability
Applies to all rental
units; exceptions for
units with regulatory
agreements (e.g.
Section 8,
government owned
and operated) and
owner-occupied
units
Applies to all rental
units; exceptions for
units with regulatory
agreements (e.g.
Section 8,
government owned
and operated) and
owner-occupied
units
Tenants with at
least two years
of tenancy
Properties
containing at least
three dwelling units;
exceptions for units
with regulatory
agreements (e.g.
Section 8,
government owned
and operated) and
accessory dwelling
units and junior
second units
Business License
Requirement
Yes Yes No Yes
Noticing Required to
the Tenant
Yes Yes Yes Yes
Copy of eviction
notice sent to the
City / County
Yes No No Yes
Reasons for
Eviction
Failure to pay rent;
breach of rental
contract; tenant
illegal activities;
violations of the
health and safety
code; failure to allow
landlord access;
tenant rejected
written lease
extension; tenant
violated occupancy
restriction; landlord
returning from
sabbatical to occupy
unit; landlord
returning from
deployment;
landlord
condominium
conversion
Failure to pay rent;
breach of rental
contract; tenant
illegal activities;
violations of the
health and safety
code; tenant
rejected written
lease extension;
unit will be
substantially
renovated because
it could become
unfit for human
habitation; landlord
returning from
deployment;
landlord
condominium
conversion; landlord
will remove the unit
from the market;
landlord or family
will move into the
unit
Failure to pay
rent; breach of
rental contract;
tenant illegal
activities;
nuisance; refusal
to renew lease;
refusal to provide
access;
correction of
violations;
withdrawal of unit
from the rental
market; landlord
or family will
move into the
unit
Failure to pay rent;
breach of rental
contract; tenant
illegal activities;
threat of violent
crime; nuisance
behavior
No fault reasons for
eviction
Landlord will
remove unit from
the market; landlord
or family will move
into unit; unit is
temporarily unfit for
human habitation;
---- ---- Landlords will
permanently
remove unit from
the rental market;
landlord or family
will move into the
unit; substantial
SAN RAFAEL CITY COUNCIL AGENDA REPORT / Page: 9
unit will be
substantially
renovated
rehabilitation for
health and safety
Relocation
assistance required
Yes – for no fault
evictions (except in
the case of natural
disasters beyond
the Landlord’s
control)
No No No
Anti-harassment
and retaliation
language
Yes Yes No Yes
Figure 4 highlights the diversity of policy questions that can shape Just Cause programs. Some of those
questions include:
➢ What Constitutes “Just Cause”?
Acceptable reasons for eviction under Just Cause are often divided into two categories: “For
Cause” and “No Fault.” Examples of eviction For Cause include failure to pay rent, illegal activity
in the unit, nuisance activities, or other material violations of a rental agreement. Example of No
Fault evictions include situations when an owner or relative moves into the unit or removes the
unit from the rental market under the Ellis Act. Some jurisdictions specify events that are not
grounds for eviction, such as an owner undergoing foreclosure proceedings.
➢ Can relocation assistance be required in connection with No Fault evictions?
Just Cause ordinances can include provisions to help offset relocation costs for tenants in certain
scenarios. For example, the City of Emeryville requires landlords to pay relocation assistance
when they decide to move back into or renovate a unit, which requires a tenant to move out.
➢ What data, if any regarding evictions can be collected?
Data can also be collected on evictions and lease terminations through a Just Cause ordinance.
Some jurisdictions require notice prior to every eviction while others require notices only for
specific No Fault evictions and others don’t require the jurisdiction to collect data at all. To better
understand the local rental market, some jurisdictions also require landlords to provide notice of
the applicable monthly rent at the time of eviction or applicable rents charged over some course
of the tenancy. As the City of San Rafael does not have a Housing Department or staff available
to actively monitor evictions and lease terminations, it would need to be determined what data is
being collected, for what purpose, and how time-intensive is the collection and analysis.
➢ What, if any, requirements and exemptions apply?
In some Bay Area jurisdictions, Just Cause protections are triggered only by code violations; they
prevent a landlord from a evicting a tenant without cause for a period following the submission of
a formal tenant complaint to the local agency code enforcement staff. The City of San Jose
originally adopted a Just Cause ordinance with tenant protection based on code violations, but
found it was difficult to enforce and had limited impact, therefore, they opted to revise and expand
SAN RAFAEL CITY COUNCIL AGENDA REPORT / Page: 10
the scope of their ordinance to reflect more typical penalty mechanisms for enforcement. Other
alternatives include exemptions for specific units (e.g. single family and duplex units) or
prerequisites for enrollment in Just Cause protections (e.g. tenancy in the same unit for two
consecutive years).
With respect to administration and enforcement, if the City of San Rafael adopted Just Cause for Eviction,
the administration and enforcement would be similar to what is happening with the Source of Income
Ordinance. If a tenant felt that they had been improperly evicted, either independently or with the help of
a local legal advocate like Legal Aid of Marin or Fair Housing Advocates of Northern California, they could
bring the matter before the civil court system. As mentioned above with Mandatory Mediation, if a tenant
contacted the City (currently all renter protection-related inquiries are being directed to the Director of
Homeless Planning & Outreach), staff would direct the party in question to one of these local resources.
There would also be the front-end requirement to create marketing materials and support documentation,
and cities can opt to receive copies of any eviction notices that occur under Just Cause, so there would
be an administrative impact to collect and retain these documents.
As the County of Marin worked towards passing Just Cause Eviction, they held a number of public
outreach meetings. During these meetings, some landlords and property owners expressed concerns
that the limits on evictions established by Just Cause regulations might discourage investment in rental
property, increasing operating costs and rental prices, and make it more difficult to remove problematic
tenants. Landlords have also expressed concern that adoption of a Just Cause ordinance could foretell
a future rent stabilization ordinance. Landlord organizations also pointed to existing laws that protect
renters from arbitrary or unreasonable evictions. For example, State law prohibits renters from being
evicted in retaliation for exercising protected rights such as filing a complaint about unsafe or unhealthy
living conditions.
Policy Considerations and Direction
As this report is informational, there is no formal City Council action required at this time. Instead, staff is
looking to the City Council for feedback on the proposed rental protection policies and for the City
Attorney’s office to complete a thorough analysis of those proposed policies . Overall, staff recommends
that the City Council consider directing staff to further research and return with proposed rental policies
and protections potentially modeled after the County of Marin.
Should the Council wish to proceed with a Mandatory Mediation and a Just Cause Ordinance, there are
a number of key policy issues that would need to be determined. For example, the County required
property owners covered by Just Cause to obtain a business license and to provide data to help illustrate
the rental market and evictions specifically. For the City, without current staff performing such functions,
we would need to determine: who should collect data, what kind of data, how will it be used, and what
resources exist to analyze the data so that it is useful.
Another issue relates to administration and enforcement of Mandatory Mediation, including how it is
funded. The City does not currently offer in-house mediation services, nor does it have an on-going
funding source to pay for such a new service. There would also need to be some front-end work to provide
an explanation of the process on the City’s website and to create any required support documentation.
As an example, the City of Concord’s marketing materials are included as Attachment 1.
Lastly, since its introduction in the early 1980s, mediation has become a popular and effective tool for
resolving disputes that might otherwise end up in court. In the typical mediation model, the mediation is
voluntary – not mandatory -- and the cost is equally shared by both parties. Making mediation mandatory
and/or imposing the cost on only one party would require further study by the City Attorney’s office to
SAN RAFAEL CITY COUNCIL AGENDA REPORT / Page: 11
investigate the potential consequences. Also, mediation requires three parties (including the mediator)
to be present. If mediation is mandatory, scheduling challenges could have unintended consequences
on the unlawful detainer court process, which tends to be an expedited process. This legal analysis will
need to be completed prior to coming back to the City Council.
In conclusion, the two policies described above address different issues for landlords and tenants:
Mandatory Mediation may help alleviate disputes regarding significant rent increases, while Just Cause
protections identify acceptable reasons for eviction. Because each policy addresses different but related
issues, in considering both policies together, the City Council could have a more significant impact than
simply passing one measure by itself.
Staff is seeking overall City Council feedback on the adoption of Mandatory Mediation and Just Cause
eviction. If the City Council is interested in further pursuing these policies, staff recommends that the City
Council consider directing staff to further research these items and to return with proposed rental policies
and protections potentially modeled after the County of Marin.
Should the Council desire, you may wish to consider appointing a temporary, ad-hoc City Council
Subcommittee to work with staff on these issues, similar to the recent ad-hoc subcommittee on small cell
wireless facilities.
PUBLIC OUTREACH: Staff has conducted preliminary public outreach on this matter. On January 10,
2019, the Director of Homeless Planning & Outreach, the Code Enforcement Manager, and a Code
Enforcement Officer attended a community meeting in the Canal that was hosted in Spanish and attended
by over 100 residents. There was unanimous support for these policies.
Additionally, a courtesy meeting notice was sent to the following organizations: Marin County Community
Development Agency, the Marin County Housing Authority, the League of Women Voters, EDEN
Housing, Marin Environmental Housing Collaborative, Sustainable Marin, Sustainable San Rafael, Fair
Housing of Marin, Marin Builders Association, Public Advocates, Inc., Legal Aid of Marin, Marin
Association of Realtors, Community Action Marin, Canal Alliance, the San Rafael Chamber of
Commerce, the Downtown San Rafael Business Improvement District, Marin Continuum of Housing, the
Housing Crisis Action Group, Aging Action Initiative, the Homeless Policy Steering Committee, Ritter
Center, St. Vincent’s, Homeward Bound, Buckelew Programs, the Marin Center for Independent Living,
the Marin Organizing Committee, and the Federation of San Rafael Neighborhoods.
The Director of Homeless Planning & Outreach sent a newsletter about renter challenges to the
Homeless Initiatives Newsletter distribution (approximately 3,000 subscribers), and this item was noticed
in the City Manager’s Bi-Weekly Snapshot newsletter. Based on City Council direction, staff is prepared
to conduct additional public outreach on this item.
FISCAL IMPACT: There is no fiscal impact for this informational report. There are currently unknown
costs should the City Council adopt a Mandatory Mediation Ordinance as the mediation service and
number of mediations is unknown. There are no direct administrative costs required for the primary
requirements of a Just Cause Ordinance, though there will be a time commitment from staff to create the
front-end public education materials about the new process.
RECOMMENDED ACTION: Provide comments and feedback to staff.
SAN RAFAEL CITY COUNCIL AGENDA REPORT / Page: 12
ATTACHMENTS:
1. Concord Mandatory Mediation Flier
2. County of Marin Just Cause Ordinance
3. County of Marin Mandatory Mediation Ordinance
Resources
Residential Rent Review Program/ Fair
Housing– ECHO Housing 1-855-275-3246 or
ConcordRentReview@echofairhousing.org
Residential Rent Review Ordinance–
http://www.codepublishing.com/CA/Concord
Eviction/Legal Issues– Bay Area Legal Aid
(925) 219-3325
Landlords– California Apartment Association
1-800-967-4222 or caanet.org
City of Concord Multi-Family Inspection
Program- (925) 671-3408 or
www.cityofconcord.org/MFIP
Residential Rent Review Program
Program Highlights
• Applies to all Concord rental properties with 3 or more rental units. Exceptions
apply.
• Landlords must provide tenants with City of Concord’s Notice of Availability of Rent
Review Required for the Residential Rent Review Program at the same time as a rent
increase notice in order to inform tenants of the Program in writing. If the notice is
not provided at the same time as the rent increase notice, the rent increase
is not allowed at that time. A copy of this notice can found at:
www.cityofconcord.org/Housing
• Landlords must provide tenants with 30 days’ notice prior to a rent increase of 10% or
less, and 60 days’ notice prior to a rent increase of more than 10%.
• Participation in the Residential Rent Review Program is voluntary for tenants, but is
mandatory for property owners.
** Does your apartment need repair? The City of Concord also has a Multi-Family Inspection Program
which helps Concord tenants live in safer, healthier and better kept multi-family housing. We look inside
and outside of the unit and identify basic maintenance items such as smoke and CO2 alarms, electrical
safety, sanitation and conditions of doors and windows. For more information, please contact the Multi-
Family Inspection Program at (925) 671-3408 or www.cityofconcord.org/MFIP**
City of Concord Housing Division
Concord Administration Building
1950 Parkside Drive MS / 10A
Concord, CA 94519
Phone: (925) 671-3387
Email: Sophia.Sidhu@cityofconcord.org
Website: www.cityofconcord.org/Housing
Welcome to the Residential Rent Review Program!
If you have been notified about a rent increase of more than 10% in a 12-month
period, this Program could possibly help you negotiate a lower rent increase.
To see if the Residential Rent Review Program can help you, please contact ECHO
Housing at 1-855-275-3246 or ConcordRentReview@echofairhousing.org
Recursos
Evaluación de Rentas Residenciales-
“ECHO Housing” 1-855-275-3246 o
ConcordRentReview@echofairhousing.org
Ordenanza de Evaluación de Rentas
Residenciales-
http://www.codepublishing.com/CA/Concord
Desalojo/Asuntos Legales- Ayuda Legal
del Área De la Bahía (“Bay Area Legal Aid”)
925-219-3325
Propetarios- Asociacion de Apartamentos
de California 1-800-967-4222 o caanet.org
Programa de Inspección Multifamiliar
de la Ciudad de Concord - (925) 671-3408
o www.cityofconcord.org/MFIP
Programa de Evaluación de Rentas Residenciales
Aspectos destacados del programa
• Se aplica a todas las propiedades de alquiler de Concord con 3 o más unidades de
alquiler. Se aplican excepciones.
• Los propietarios deben proporcionar a los inquilinos el Aviso de disponibilidad de
evaluacion de renta requerido por la Ciudad de Concord para el programa de
evaluación de rentas residenciales al mismo tiempo que un aviso de aumento de renta para
informar a los inquilinos del programa por escrito. Si el aviso no se proporciona al
mismo tiempo que el aviso de aumento de renta, el aumento de renta no está
permitido en ese momento. Se puede encontrar una copia de este aviso en:
www.cityofconcord.org/Housing
• Los propietarios deben proporcionar a los inquilinos un aviso con 30 días de anticipación
antes de un aumento de renta de 10% o menos, y un aviso de 60 días antes de un
aumento de renta que es más de 10%.
• La participación en el Programa de Evaluación de Rentas Residenciales es voluntaria para
los inquilinos, pero obligatoria para dueños de propiedades/propietarios.
**¿Necesita reparar su apartamento? La ciudad de Concord también tiene un Programa de
Inspección Multifamiliar que ayuda a los inquilinos de Concord a vivir en viviendas multifamiliares
más seguras, saludables y mejor conservadas. Para más información, por favor póngase en contacto
con el Programa de Inspección Multifamiliar al (925) 671-3408 o www.cityofconcord.org/MFIP**
Cuidad de Concord División de
Vivienda
Edificio de Administración
1950 Parkside Drive MS / 10A
Concord, CA 94519
Teléfono: (925) 671-3387
Correo electrónico:
Sophia.Sidhu@cityofconcord.org
Sitio Web: www.cityofconcord.org/Housing
Bienvenido al Programa de Evaluación de Rentas Residenciales
Si le han notificado sobre un aumento de su renta que es más de 10% en un período de 12
meses, este programa podría ayudarle a negociar un aumento de renta más bajo.
Para ver si el programa de Evaluación de Rentas Residenciales puede ayudarle, por favor
comuníquese con “ECHO Housing” al 1-855-275-3246 o por correo electrónico al
ConcordRentReview@echofairhousing.org
Page 1 of 12
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ORDINANCE NO. _____
ORDINANCE OF THE MARIN COUNTY BOARD OF SUPERVISORS
ADDING COUNTY OF MARIN CODE OF ORDINANCES CHAPTER 5.100,
REQUIRING CAUSE TO TERMINATE A RESIDENTIAL TENANCY
SECTION I: LEGISLATIVE FINDINGS
WHEREAS, over 67,000 people permanently reside in the unincorporated area
within Marin County, which population is projected to grow by approximately 10,000
additional residents by 2040, as identified in Section II: Housing Needs Analysis of the
Marin County Housing Element 2015-2023; and
WHEREAS, over thirty percent of the 26,000 households that reside in
unincorporated Marin rent their homes, as identified in Section II: Housing Needs Analysis
of the Marin County Housing Element 2015-2023; and
WHEREAS, it is estimated that over 2,000 households residing in unincorporated
Marin have extremely low incomes, which is defined as earning approximately thirty
percent of the area median income, as identified in Section II: Housing Needs Analysis of
the Marin County Housing Element 2015-2023; and
WHEREAS, approximately fifty-six percent of renters in 2010 were estimated to
be overpaying for rental housing, which is defined as paying more than thirty percent of
household income as rent, as identified in Section II: Housing Needs Analysis of the Marin
County Housing Element 2015-2023; and
WHEREAS, between 2001 and 2013 home values increased significantly more
than area incomes, as identified in Section II: Housing Needs Analysis of the Marin
County Housing Element 2015-2023; and
WHEREAS, between 2004 and 2013 rental prices increased approximately
thirteen percent, as identified in Section II: Housing Needs Analysis of the Marin County
Housing Element 2015-2023; and
WHEREAS, there is a shortage of rental housing, including multi-family, single-
family, second units, and Single Room Occupancy (SRO) units, as identified in Section
II: Housing Needs Analysis of the Marin County Housing Element 2015 -2023; and
WHEREAS, increasing rental prices combined with the constrained supply of
rental housing in the County can result in displacement of County residents beyond the
County and region if a household's tenancy is terminated without a cause, with impacts
particularly affecting low- and moderate-income households; and
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WHEREAS, a 2018 research project by the California Housing Partnership and
U.C. Berkeley's Urban Displacement Project regarding Rising Housing Costs and Re -
segregation showed that displaced households experienced greater housing cost s after
displacement, whether they moved within their county of origin, to a new county in the
Bay Area, within the region, or out of state;1 and
WHEREAS, the County's Rental Housing Survey released in 2015 received more
than 800 tenant responses, and found that 372 (45 percent) were concerned with
insecurity and instability of their rental home, and 59 percent of all respondents were
worried about rent increases and/or evictions; and
WHEREAS, 1,296 unlawful detainer actions were filed in Marin County b etween
2014 and 2016, which indicates over 400 unlawful detainer actions may be filed each
year;2 and
WHEREAS, unlawful detainer actions filed with the courts do not account for the
terminations of tenancy, notices to quit, and other actions that can resul t in the
displacement of County residents generally, and which particularly impact members of
protected classes in Marin County; and
WHEREAS, for the past approximately three years, the Board of Supervisors has
been considering a slate of policy options to preserve housing affordability and prevent
displacement, and has taken action to implement several measures in furtherance of
these goals based in part on recommendations from an ad hoc Affordable Housing
Subcommittee of the Board; and
WHEREAS, the Board of Supervisors discussed just cause for eviction policies
during seven workshops, held in October and December 2015, February 2016, August
and December 2017, and in June and September 2018; and
WHEREAS, the Community Advisory Group and Steering Committee for the
County's ongoing Assessment of Fair Housing identified just cause for eviction policies
as one priority recommendation to promote fair housing after extensive community
engagement process reaching over 1,400 people from all areas of the County; a nd
WHEREAS, just cause for eviction policies continue to allow landlords to terminate
tenancies and evict tenants based on a tenant's failure to pay rent or illegal activities, a
landlord's desire to withdraw the property from the rental market, and other specified
reasons, while providing tenants with more stability and security; and
1 Zuk, M., & Chapple, K. (2018). Urban Displacement Project. Retrieved from
http://www.urbandisplacement.org/research#section-132. Published research only for San Francisco,
Alameda, and Contra-Costa Counties, but presented at Non-Profit Housing Conference applied to Bay
Area generally.
2 Research from Anti-Eviction Mapping Projection and Tenants Together (May 2018). Retrieved from
https://www.antievictionmap.com/evictions#/unlawful-detainer-evictions-california-20142016.
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WHEREAS, just cause for eviction policies advance fair housing policy by:
increasing transparency and reducing the chance that a termination of tenancy or eviction
is motivated by unlawful discrimination or retaliation; specifically protecting existing
tenants who are statistically more likely to be members of protected classes than
homeowners in Marin County due to historical housing policies; and
WHEREAS, on September 11, 2018, the Board of Supervisors held a workshop
and received public testimony on Just Cause for Eviction policies and directed staff to
develop a Just Cause Ordinance, with further direction from the Affordable Housing
Subcommittee of the Board; and
WHEREAS, the Board of Supervisors has identified six specific causes for which
a tenancy may be terminated that balance the needs of property owners, market
conditions, and protections for the renter population in the unincorporated area of the
County; and
WHEREAS, the Board of Supervisors conducted duly and properly noticed public
hearings on December 4 and December 18, 2018 regarding an ordinance requiring cause
to terminate a residential tenancy; and
WHEREAS, the Board of Supervisors finds and determines that regulating the
reasons for terminating a tenancy between certain residential landlords and residential
tenants will increase certainty and fairness within the residential rental market in the
County and thereby serve the public peace, health, safety, and public welfare; and
WHEREAS, Chapter 5.100 is adopted and added to the County of Marin Code of
Ordinances pursuant to the County's police powers, afforded by the state constitution and
state law, to protect the health, safety, and welfare of the public.
SECTION II: ACTION
The Marin County Board of Supervisors ordains as follows: Ordinance No. [ ] is hereby
adopted and Chapter 5.100 Requiring Cause to Terminate a Residential Tenancy shall
be codified in the Marin County Code of Ordinances in the form attached a s Exhibit "A"
to Marin County Ordinance No. [ ].
SECTION III: CEQA DETERMINATION
The Board of Supervisors finds that adoption of this Ordinance is exempt from the
California Environmental Quality Act ("CEQA") pursuant to section 15061(b)(3) of the
State CEQA Guidelines because it can be seen with certainty that there is no possibility
that the adoption of this Ordinance may have a significant effect on the environment, in
that this ordinance applies residential tenant protection measures to existing resid ential
units in unincorporated areas of Marin County, which is solely an administrative process
resulting in no physical changes to the environment. Accordingly, this ordinance contains
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no provisions modifying the physical design, development, or construct ion of residences
or nonresidential structures.
SECTION IV: SEVERABILITY
Every section, paragraph, clause, and phrase of this Ordinance is hereby declared to be
severable. If for any reason, any section, paragraph, clause, or phrase is held to be invalid
or unconstitutional, such invalidity or unconstitutionality shall not affect the validity or
constitutionality of the remaining sections, paragraphs, clauses or phrases.
SECTION V: EFFECTIVE DATE AND PUBLICATION
This Ordinance shall be and is hereby declared to be in full force and effect as of thirty
(30) days from and after the date of its passage and shall be published once before the
expiration of fifteen (15) days after its passage, with the names of the Supervisors voting
for and against the same, in the Marin Independent Journal, a newspaper of general
circulation published in the County of Marin.
SECTION VI: VOTE
PASSED AND ADOPTED at a regular meeting of the Board of Supervisors of the
County of Marin, State of California, on this __ day of ______________ 2018 by the
following vote:
AYES: SUPERVISORS
NOES:
ABSENT:
DAMON CONNOLLY, PRESIDENT
MARIN COUNTY BOARD OF SUPERVISORS
ATTEST:
Matthew H. Hymel
Clerk of the Board of Supervisors
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EXHIBIT "A" TO MARIN COUNTY ORDINANCE NO. [ ]
Marin County Code of Ordinances Chapter 5.100
Requiring Cause to Terminate a Residential Tenancy
Section: 5.100.010 Purpose and intent.
(a) It is the purpose and intent of this Chapter to increase certainty and fairness in the
residential rental market within unincorporated Marin County in order to promote
the health, safety, and general welfare of residents and property owners within the
County. This Chapter regulates the reason(s) for and defines certain minimum
term(s) under which certain residential tenancies may be terminated by Landlords
of rental Dwelling Units located within unincorporated Marin County.
(b) The CDA Director has the authority to issue interpretations of and regulations to
implement this Chapter, including the publication of form notices and other
documents. All forms and notices called for to facilitate the administration and
implementation of this Chapter shall be adopted by the CDA Director, with approval
by the County Counsel, and included in the Guidelines.
Section: 5.100.020 Applicability.
(a) General Application. Except as provided in Section 5.100.020(b) below, the
provisions of this Chapter 5.100 shall apply to all properties in unincorporated
Marin County that contain at least three: (1) Dwelling Units which contain a
separate bathroom, kitchen, and living area in a multifamily or multipurpose
dwelling; (2) Dwelling Units in Single Room Occupancy residential structures; or
(3) units in a structure that is being used for residential uses whether or not the
residential use is a conforming use permitted under the Marin County Code of
Ordinances, which is hired, rented, or leased to a household within the meaning of
California Civil Code section 1940. This definition applies to any dwelling space
that is actually used for residential purposes, including live-work spaces, whether
or not the residential use is legally permitted.
(b) Exceptions. Notwithstanding anything to the contrary above, the provisions of this
Chapter 5.100 shall not apply to the following types of Dwelling Units:
(1) Any Dwelling Unit for which one of the following is true: (A) the Dwelling Unit
is owned or operated by any government agency; or (B) the Rent is directly
subsidized by a government agency such that the Tenant's portion of the
Rent does not exceed 30% of household income; or
(2) Any Dwelling Unit located in a development where no fewer than forty-nine
percent (49%) of the Dwelling Units are subject to legally binding restrictions
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Attachment No. 1
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enforceable against and/or governing such units that limit the Rent to no
more than an affordable rent, as such term is defined in California Health &
Safety Code Section 50053; or
(3) Any residential accessory dwelling unit or junior accessory dwelling unit,
each as defined in Marin County Development Code Chapter 22.56; or
(4) Any Dwelling Unit occupied by a Tenant employed by the Landlord for the
purpose of managing the property.
Section: 5.100.030 Definitions.
For the purpose of this Chapter, the following words and phrases shall mean:
(a) "County" means the County of Marin.
(b) "CDA Director" means the County of Marin Community Development Agency
Director or his or her designee unless otherwise specified.
(c) "Dwelling Unit" means a structure or the part of a structure that is used as a home,
residence, or sleeping place by one person who maintains a household or by two
or more persons who maintain a common household as defined in California Civil
Code section 1940 and the Marin County Code.
(d) "For Cause" termination has the meaning provided in subsection (b) of Section
5.100.040.
(e) "Guidelines" means any written regulations for the administration and
implementation of this Chapter adopted by the CDA Director.
(f) "Landlord" means an owner, lessor, or sublessor who receives or is entitled to
receive Rent for the use and occupancy of any Dwelling Unit or portion thereof.
(g) "No Fault" termination has the meaning provided in subsection (c) of Section
5.100.040.
(h) "Notice of Termination" means a written notice that includes all of the components
identified in Section 5.100.050.
(i) "Primary Residence" means a Dwelling Unit that an owner occupies as a primary
residence, as evidenced by the Dwelling Unit qualifying for a homeowner's
property tax exemption.
(j) "Rent" means the consideration, including any funds, labor, bonus, benefit, or
gratuity, demanded or received by a Landlord for or in connection with the use and
occupancy of a Dwelling Unit and the Housing Services provided therewith, or for
the assignment of a rental agreement for a Dwelling Unit.
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(k) "Tenant" means a person entitled by written or oral agreement, or by sufferance,
to the use or occupancy of a Dwelling Unit.
(l) "Tenant Household" means all Tenant(s) who occupy any individual Dwelling Unit,
and each minor child, dependent, spouse or registered domestic partner of any
Tenant whose primary residence is the Dwelling Unit.
Section: 5.100.040 Cause required to terminate tenancy.
(a) Prerequisites to terminate. No Landlord may terminate a residential tenancy of a
Dwelling Unit unless the Landlord can demonstrate:
(1) the Landlord possesses a valid Business License in accordance with
Chapter 5.54 of the County Code; and
(2) the Landlord has previously provided the Tenant with the Notice of Tenant
Rights as required by County Code Section 5.95.080, or can otherwise
demonstrate timely, good faith substantial compliance with the noticing
requirements listed herein; and
(3) the Landlord served a Notice of Termination to the Tenant, in the form
required by County Code Section 5.100.050, and that the Landlord
delivered a true and accurate copy of the Notice of Termination to the CDA
Director within ten (10) calendar days of delivery to the Tenant(s); and
(4) the Landlord has not accepted and will not accept rent or any other
consideration in return for the continued use of the Dwelling Unit beyond
the term of the terminated tenancy in compliance with California Civil Code
sections 1945, 1946, and 1946.1; and
(5) the termination qualifies as a For Cause or No Fault termination, as defined
in this Section; and
(6) for all Notices of Termination served to the Tenant after June 1, 2019, the
Landlord must have registered the Dwelling Unit in accordance with Section
5.100.080 of this Chapter; and
(7) the Landlord has complied with the requirements listed in Section 5.100.090
of this Chapter.
(b) For Cause Terminations. If a Landlord can show any of the following
circumstances with respect to a termination of tenancy, the termination will qualify
as "For Cause." Nothing in this section shall abrogate the protections afforded to
survivors of violence consistent with the California Code of Civil Procedure Section
1161.3, as amended, and the Violence Against Women Act, Pu blic Law 102-322,
as amended.
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(1) Failure to Pay Rent. Tenant failed to pay Rent within three days of receiving
written notice from the Landlord demanding payment as provided in
subsection 2 of California Code of Civil Procedure section 1161.
(2) Breach of Rental Contract. Tenant violated a material term of the rental
agreement as provided in subsection 3 of California Code of Civil Procedure
section 1161.
(3) Tenant Illegal Activities. Tenant has been convicted for using the Dwelling
Unit for an illegal purpose as provided in subsection 4 of California Code of
Civil Procedure section 1161, including but not limited to the unlawful
distribution of a controlled substance as contemplated by California Civil
Code section 3486, the unlawful use, manufacture, or possession of
weapons and ammunition as contemplated by California Civil Code section
3485, or for of a serious crime or violent felony as defined by applicable law,
which occurred during the tenancy and within 1,000 feet of the Dwelling
Unit. For purposes of this subsection, Tenant Household, after receiving a
written notice, may cure the violation by removing, and demonstrating such
removal, of the offending Tenant.
(4) Threat of Violent Crime. Any statement made by a Tenant, or at his or her
request, by his or her agent to any person who is on the property that
includes the unit or to the Landlord, or his or her agent, threatening the
commission of a crime which will result in death or great bodily injury to
another person, with the specific intent that the statement is to be taken as
a threat, even if there is no intent of actually carrying it out, when on its face
and under the circumstances in which it is made, it is so unequivocal,
immediate and specific as to convey to the person threatened, a gravity of
purpose and an immediate prospect of execution of the threat, and thereby
causes that person reasonably to be in sustained fear for his or her own
safety or for his or her immediate family's safety.
(5) Nuisance Behavior. The Tenant, after written notice to cease and the
passage of a reasonable period of time to abate or cure, continues to be so
disorderly or to cause such a nuisance as to destroy the peace, quiet,
comfort, or safety of the Landlord or other Tenants of the structure or rental
complex containing the Dwelling Unit. Such nuisance or disorderly conduct
includes violations of state and federal criminal law that destroy the peace,
quiet, comfort, or safety of the Landlord or other Tenants of the structure or
rental complex containing the Dwelling Unit, or the creation or maintenance
of a dangerous or unsanitary condition in violation of applicable local, state,
and Federal law, and may be further defined in the regulations adopted by
the Community Development Director.
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(6) Notwithstanding the limitations of California Code of Civil Procedure Section
1161.3, as amended, act or acts constituting domestic violence or sexual
assault or stalking against the Tenant or a member of Tenant's household
cannot form the substantial basis of a For Cause reason to terminate the
tenancy of the victim of such acts. A member of a Tenant household may
raise such facts as an affirmative defense to an action terminating the
tenancy.
(c) No Fault Terminations. If a Landlord can show any of the following circumstances
with respect to a termination of tenancy, the termination will qualify as "No Fault."
(1) Landlord Will Permanently Remove Unit from Rental Market. Landlord will
imminently demolish the Dwelling Unit or otherwise permanently remove
the Dwelling Unit from any residential rental use or purpose, in accordance
with California Government Code sections 7060 – 7060.7.
(2) Landlord Will Move in to Dwelling Unit. Landlord, or one of Landlord's
parents or children, intends to move into and reside in the Dwelling Unit as
his, her, or their Primary Residence. The Dwelling Unit must be occupied
as the Primary Residence within three months of the Tenant household
vacating the Dwelling Unit, and the Dwelling Unit must continue to be
occupied as the Primary Residence for at least one year.
(3) Substantial Rehabilitation for Health and Safety. Landlord has obtained
permits to undertake substantial repairs to the Dwelling Unit that cannot be
completed while the Dwelling Unit is occupied . To qualify, such substantial
repairs must be for the primary purpose of bringing the Dwelling Unit into
compliance with applicable health and safety codes.
(d) Buy-Out Agreements. Nothing in this Chapter shall expand or limit a Landlord and
Tenant's ability to negotiate or agree to end a tenancy voluntarily in exchange for
money or other consideration.
Section: 5.100.050 Notice of Termination.
(a) Contents of Notice of Termination. In addition to any information required by state
or federal law, each Notice of Termination subject to this Chapter must include the
following information.
(1) The name and address of the Landlord where the Landlord will accept
service of process; and
(2) The location of the Dwelling Unit; and
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(3) The total length of the notice prior to termination of tenancy (expressed as
number of days from delivery of notice until the anticipated final date of
tenancy); and
(4) The intended final date of occupancy under the tenancy; and
(5) The monthly Rent applicable to the tenancy upon delivery of the Notice,
and, if applicable, the date on which the final monthly Rent is due; and
(6) The beginning date of the tenancy and monthly Rent applicable at that time;
and
(7) One applicable cause for which the tenancy will be terminated, in
accordance with Section 5.100.040.
(b) Language of Notice of Termination. If the Tenant's rental agreement was
negotiated in a language other than English, then the Landlord is obligated to
provide an accurate translation of the Notice of Termination in the language in
which the rental agreement was negotiated.
(c) Delivery of Notice. Each Notice of Termination must be delivered to the Tenant
Household in accordance with Civil Code sections 1946 and 1946.1, as applicable.
(d) Copy of Notice to County. Landlords must provide a copy of the Notice of
Termination to the Community Development Agency within ten days of delivery to
the Tenant(s). In the event that the Landlord has identified a breach of a rental
contract as a cause for the Termination as provided in Section 5.100.040(b)(2), the
Landlord must attach a copy of the applicable rental agreement or contract to the
Notice of Termination when submitting th e Notice of Termination to the County.
Notices of Termination may be submitted via the County’s website for such Notices
or as otherwise specified in the Guidelines.
Section: 5.100.060 Extended notice for certain No Fault terminations.
Each Tenant household whose tenancy is terminated pursuant to subsection (c)(1) of
Section 5.100.040 (Landlord will permanently remove unit from rental market) must
receive notice of the termination at least one hundred twenty (120) days prior to the
intended final date of occupancy under the tenancy.
Section: 5.100.070 Civil remedies.
(a) Affirmative Defense. A Landlord's failure to comply with this Chapter, including but
not limited to the identification of an applicable cause for termination described in
Section 5.100.040 and delivery of a completed Notice of Termination in
accordance with Section 5.100.050, shall be an affirmative defense to an unlawful
detainer action by Landlord.
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(b) Civil Liability. Whenever a Landlord attempts to prevent a tenant fro m acquiring
any rights under this chapter, retaliates against a Tenant or Tenant Household for
the exercise of any rights under this chapter, or engages in activities prohibited
under this chapter, the Tenant, Tenant Household, or the County may institute a
civil proceeding for money damages or injunctive relief, or both . This section
creates a private right of action to enforce all terms, rights, and obligations under
this chapter. Whoever is found to have violated this chapter shall be subject to
appropriate injunctive relief and shall be liable for damages, costs and reasonable
attorneys’ fees, and whatever other relief the court deems appropriate. In the case
of an award of damages, said award may be trebled if the trier of fact finds that the
Landlord acted in knowing violation, reckless disregard, or otherwise willfully failed
to comply with this chapter.
(c) Authorization of County to Enforce the Ordinance. The County shall have the right
and authority, but not the obligation, to enforce provisions of this chapter to bring
actions for injunctive relief on behalf of the County or on behalf of Tenants or
Tenant Households seeking compliance by Landlords with this chapter or through
administrative remedy or citation.
(d) Civil Action to Determine Liability. Any Tenant may bring a civil action to determine
the applicability of this chapter to the tenancy.
(e) Other Private Rights of Action. Nothing herein shall be deemed to interfere with
the right of a Landlord to file an action against a Tenant or non-Tenant third party
for the damage done to said Landlord’s property. Nothing herein is intended to limit
the damages recoverable by any party through a private action.
Section: 5.100.080 Rental Dwelling Unit registry.
No later than June 1, 2019, and on or before January 1 of each year thereafter, each
person or entity seeking to Rent or lease one or more Dwelling Units on properties that
are subject to the provisions of this Chapter to a residential Tenant must register their
unit(s), using forms provided by the County. Each addition to the registry must include, at
a minimum, the following information provided under penalty of perjury and certified to be
true as of November 1 of the preceding year:
(a) the name, address, and phone number of the person(s) that own the Dwelling Unit
to be rented, if other than a natural person then the name of the entity and the
name and address of the designated agent for service of process; and
(b) the address of each Dwelling Unit for rent or lease; and
(c) the number of bedrooms in each Dwelling Unit for rent or lease; and
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(d) the amount and date of the monthly Rent received for each Dwelling Unit,
identifying whether the monthly Rent includes specified utilities (water/sewer,
refuse/recycle, natural gas, electricity, etc.); and
(e) the occupancy status of each Dwelling Unit (e.g. vacant or occupied); and
(f) the address of all other Dwelling Units owned in the County; and
(g) the Business License number applicable to each above -referenced Dwelling Unit
in accordance with Chapter 5.54 of the County Code.
Section: 5.100.090 Compliance with other local regulations
In addition to the requirements of this Chapter, properties subject to the provisions of this
Chapter shall also comply with all other applicable regu lations, including but not
necessarily limited to maintaining a valid business license and a valid Permit to Operate
from Marin County Environmental Health Services Division.
Section: 5.100.100 Severability.
The provisions of this Chapter are declared to be severable. If for any reason, any section,
paragraph, clause, or phrase of this Chapter or the application thereof to any person,
entity, or circumstance is held to be invalid or unconstitutional, such invalidity or
unconstitutionality shall not affect the validity or constitutionality of the remaining sections,
paragraphs, clauses or phrases.
Section: 5.100.110 Ordinance review.
This Chapter shall be reviewed by the Board of Supervisors no later than January 18,
2021, at which time the Board of Supervisors may consider revisions to this Chapter.
ORDINANCE NO. _____
ORDINANCE OF THE MARIN COUNTY BOARD OF SUPERVISORS
AMENDING COUNTY OF MARIN CODE OF ORDINANCES CHAPTER 5.95,
RENTAL HOUSING DISPUTE RESOLUTION
SECTION I: LEGISLATIVE FINDINGS
1. WHEREAS, over 67,000 people permanently reside in the unincorporated area within
Marin County, which population is projected to grow by approximately 10,000 additional residents
by 2040, as identified in Section II: Housing Needs Analysis of the Marin County Housing Element
2015 – 2023; and
2. WHEREAS, over 30 percent of the 26,000 households that reside in unincorporated Marin
rent their homes, as identified in Section II: Housing Needs Analysis of the Marin County Housing
Element 2015 – 2023; and
3. WHEREAS, it is estimated that over 2,000 households residing in unincorporated Marin
have extremely low incomes, which is defined as earning approximately 30 percent of the area
median income, as identified in Section II: Housing Needs Analysis of the Marin County Housing
Element 2015 – 2023; and
4. WHEREAS, approximately 56 percent of renters in 2010 were estimated to be overpaying
for rental housing, which is defined as paying more than 30 percent of household income as rent,
as identified in Section II: Housing Needs Analysis of the Marin County Housing Element 2015 –
2023; and
5. WHEREAS, between 2001 and 2013 home values increased significantly more than area
incomes, as identified in Section II: Housing Needs Analysis of the Marin County Housing Element
2015 – 2023; and
6. WHEREAS, between 2004 and 2013 rental prices increased approximately 13 percent,
as identified in Section II: Housing Needs Analysis of the Marin County Housing Element 2015 –
2023; and
7. WHEREAS, there is a shortage of rental housing, including multi-family, single-family,
second units, and Single Room Occupancy (SRO) units, as identified in Section II: Housing Needs
Analysis of the Marin County Housing Element 2015 – 2023; and
8. WHEREAS, for the past approximately two years, the Board of Supervisors has been
considering a slate of policy options to preserve housing affordability and prevent displacement,
and has taken action to implement several measures in furtherance of these goals based in part
on recommendations from an Affordable Housing Subcommittee of the Board; and
9. WHEREAS, on November 2, 2017, the Affordable Housing Board Subcommittee
recommended that the County establish a Rental Housing Dispute Resolution program consisting
of mandatory mediation and certain tenant protection policies; and
10. WHEREAS, the Board of Supervisors finds and determines that regulating the relations
between certain residential landlords and residential tenants will increase certainty and fairness
within the residential rental market in the County and thereby serve the public peace, health,
safety, and public welfare; and
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11. WHEREAS, on December 12, 2017 the Board of Supervisor adopted Ordinance 3680,
and thereby added Chapter 5.95, titled “Rental Housing Dispute Resolution,” to the Marin County
Code of Ordinances pursuant to the County's police powers, afforded by the state constitution
and state law, to protect the health, safety, and welfare of the public; and
12. WHEREAS, the proposed amendment would simplify the eligibility criteria and clarify
certain provisions that define Good Faith Participation in the program; and
13. WHEREAS, the Board of Supervisors conducted duly and properly noticed public hearings
on August 7 and 21, 2018 regarding the Rental Housing Dispute Resolution program; and
14. WHEREAS, Chapter 5.95 of the County of Marin Code of Ordinances is amended.
SECTION II: ACTION
The Marin County Board of Supervisors ordains as follows: Ordinance No. [ ] is hereby adopted
and Chapter 5.95 Rental Housing Dispute Resolution shall be codified in the Marin County Code
of Ordinances in the form attached as Exhibit "A" to Marin County Ordinance No. [ ].
SECTION III: CEQA DETERMINATION
The Board of Supervisors finds that adoption of this Ordinance is exempt from the California
Environmental Quality Act ("CEQA") pursuant to section 15061(b)(3) of the State CEQA
Guidelines because it can be seen with certainty that there is no possibility that the adoption of
this Ordinance may have a significant effect on the environment, in that this ordinance applies
residential tenant protection measures to existing residential units in unincorporated areas of
Marin County, which is solely an administrative process resulting in no physical changes to the
environment. Accordingly, this ordinance contains no provisions modifying the physical design,
development, or construction of residences or nonresidential structures.
SECTION IV: SEVERABILITY
Every section, paragraph, clause, and phrase of this Ordinance is hereby declared to be
severable. If for any reason, any section, paragraph, clause, or phrase is held to be invalid or
unconstitutional, such invalidity or unconstitutionality shall not affect the validity or constitutionality
of the remaining sections, paragraphs, clauses or phrases.
SECTION V: EFFECTIVE DATE AND PUBLICATION
This Ordinance shall be and is hereby declared to be in full force and effect as of 30 days from
and after the date of its passage and shall be published once before the expiration of 15 days
after its passage, with the names of the Supervisors voting for and against the same, in the Marin
Independent Journal, a newspaper of general circulation published in the County of Marin.
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Ordinance No. [ ]
SECTION VI: VOTE
PASSED AND ADOPTED at a regular meeting of the Board of Supervisors of the County
of Marin, State of California, on this 21st day of August 2018 by the following vote:
AYES: SUPERVISORS
NOES:
ABSENT:
DAMON CONNOLLY, PRESIDENT
MARIN COUNTY BOARD OF SUPERVISORS
ATTEST:
Matthew H. Hymel
Clerk of the Board of Supervisors
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Ordinance No. [ ]
EXHIBIT "A" TO MARIN COUNTY ORDINANCE NO. [ ]
Marin County Code of Ordinances Chapter 5.95
Rental Housing Dispute Resolution
Section: 5.95.010 Purpose and intent.
It is the purpose and intent of this Chapter to increase certainty and fairness in the residential
rental market within unincorporated Marin County, in order to promote the health, safety, and
general welfare of residents and businesses within the County. This Chapter only governs
disputes between Landlords and Tenants of rental Dwelling Units located within unincorporated
Marin County.
Section: 5.95.020 Applicability.
The provisions of this Chapter 5.95 shall apply to all Dwelling Units in unincorporated Marin
County containing a separate bathroom, kitchen, and living area, including a single-family dwelling
or unit in a multifamily or multipurpose dwelling, a unit in a condominium or cooperative housing
project, or a unit in a structure that is being used for residential uses whether or not the residential
use is a conforming use permitted under the Marin County Code of Ordinances, which is hired,
rented, or leased to a household within the meaning of California Civil Code Section 1940. This
definition applies to any dwelling space that is actually used for residential purposes, including
live-work spaces, whether or not the residential use is legally permitted.
Notwithstanding anything to the contrary above, the provisions of this Chapter 5.95 shall not apply
to the following:
(a) Any Dwelling Unit that is owned or operated by any government agency; or
(b) Any Dwelling Unit for which one of the following is true (1) t he Rent is limited to no more
than affordable rent, as such term is defined in California Health & Safety Code Section
50053, pursuant and subject to legally binding restrictions enforceable against and/or
governing such units; or (2) the Rent is directly subsidized by a government agency such
that the Tenant's portion of the Rent does not exceed 30% of income.
Section: 5.95.030 Definitions.
For the purpose of this Chapter, the following words and phrases shall mean:
(a) "County" means the County of Marin.
(b) "CDA Director" means the County of Marin Community Development Agency Director or
their designee unless otherwise specified.
(c) "Designated Service Provider" means a party, organization, or County Department
selected by the CDA Director to provide Mediation services and other tasks necessary to
implement the program and procedures contained in this Chapter and any associated
Guidelines.
(d) "Dwelling Unit" means a structure or the part of a structure that is used as a home,
residence, or sleeping place by one person who maintains a household or by two or more
persons who maintain a common household as defined in California Civil Code section
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1940 and County Code sections 18.10.020, 20.16.061, including those dwellings defined
in County Code sections 22.02.2401 (Dwelling, one-family), 22.02.2501 (Dwelling, two-
family), and 22.02.2601 (Dwelling, multiple).
(e) "Guidelines" means any written regulations for the administration and implementation of
this Chapter adopted by the CDA Director. All forms and notices called for to facilitate the
administration and implementation of this Chapter shall be adopted by the CDA Director,
with approval by the County Counsel, and included in the Guidelines.
(f) “Good Faith” participation includes the affirmative duty of the Landlord to: (i) refrain from
any harassment or other prohibited activity described in Section 5.95.060 and to (ii) refrain
from an unlawful detainer proceeding while the parties are engaged in proceedings under
this Chapter excepting only those actions authorized by subsections (3) and (4) of
California Code of Civil Procedure section 1161 or any successor provisions. Good Faith
participation also includes the affirmative duty of the Tenant to abide by the terms of the
lease or rental agreement and to pay all lawful Rent owed.
(g) "Landlord" means an owner, lessor, or sublessor who receives or is entitled to receive
Rent for the use and occupancy of any Dwelling Unit or portion thereof.
(h) "Mediation" means one or more meetings in which a Landlord and Tenant have the
opportunity to directly communicate with a Mediator and each other in a face-to-face
setting at a neutral location in order to resolve a rental housing dispute under ground rules
designed to protect the confidentiality and neutrality of the communications.
(i) "Mediator" means a person who is employed by the Designated Service Provider and who
meets any criteria for conducting Mediations that may be established in the Guidelines.
(j) "Rent" means the consideration, including any funds, labor, bonus, benefit, or gratuity,
demanded or received by a Landlord for or in connection with the use and occupancy of
a Dwelling Unit and the Housing Services provided therewith, or for the assignment of a
rental agreement for a Dwelling Unit.
(l) "Tenant" means a person entitled by written or oral agreement, or by sufferance, to the
use or occupancy of a Dwelling Unit.
Section: 5.95.040 Mediation eligibility.
(a) Tenant-initiated Mediation. A Tenant residing in a Dwelling Unit may file a request and
receive Mediation services within either 30 calendar days from the enactment of this
Chapter or ten calendar days of the Tenant's receipt of one or more notices in accordance
with California Civil Code section 827 that individually or cumulatively increase Rent more
than five percent within any 12-month period.
(b) Landlord-requested Mediation. Any Landlord may file a request and receive Mediation
services in order to pursue a Rent increase greater than five percent within any 12-month
period.
Section: 5.95.050 Mediation process.
(a) Designated Service Provider. The CDA Director shall contract with or designate a
Designated Service Provider to provide Mediation services. The Guidelines may include
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a description of minimum qualifications for the Designated Service Provider and its
Mediators.
(b) Mediation Requests.
(1) Any Tenant or Landlord eligible for Mediation under Section 5.95.040 may request
Mediation services from the Designated Service Provider.
(2) Each Landlord and/or Tenant requesting Mediation services must complete and
sign a form under penalty of perjury that demonstrates eligibility for Mediation
under this Chapter and includes other information as may be specified in the
Guidelines.
(3) Separate requests for Mediation services that involve one or more of the same
parties may be consolidated with the consent of the Landlord and the other
Tenant(s), but consolidation is not required and shall not affect individuals' ability
to be separately represented or to bring a separate legal action.
(4) If an eligible Tenant has requested Mediation as a result of receiving one or more
notices in accordance with California Civil Code section 827 that individually or
cumulatively increase Rent more than five percent within any 12-month period,
unless the parties otherwise agree in writing, such noticed Rent increase will not
be effective until the Mediation concludes.
(c) Two-Step Mediation Process. The Designated Service Provider shall assign a Mediator
within ten calendar days of receiving a complete request for Mediation services. The
assigned Mediator shall offer a two-step Mediation process as follows:
(1) Within two business days of receiving a Mediation assignment from the Designated
Service Provider, the Mediator shall provide notice of the Mediation to the Landlord
and Tenant. The Mediation notice shall, at a minimum, inform each party of their
obligation to appear at the Mediation and participate in the Mediation in Good
Faith. The Mediator shall make reasonable efforts to schedule Mediation sessions
at times that are mutually convenient for the Landlord and the Tenant, which may
include times that are outside of business hours. The Mediation process shall
commence upon notification of the Landlord and Tenant by the Mediator.
(A) A Mediator may notify the Landlord and/or Tenant of the Mediation process
via telephone, email, or any other form of communication, but at a
minimum, the Mediator must notify each party in writing via first-class mail,
postage prepaid to each parties' address of record.
(B) Following the Mediator sending such notification, both the Landlord and the
Tenant have an affirmative obligation to participate in the Mediation in
Good Faith until the Mediation concludes.
(2) The Mediation process shall conclude upon the earlier of: (A) the execution of a
legally enforceable, written Mediation agreement signed by all parties to the
Mediation service under Section 5.95.050(e); (B) the Mediator's determination that
no further progress is likely to result from continued Mediation; or (C) all of the
parties to the Mediation indicate in writing that the Mediation has concluded to their
satisfaction. In no event shall a Mediation process last longer than 30 calendar
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days from when the parties are notified unless the parties agree in writing to extend
the Mediation term. If no legally enforceable, written Mediation agreement is
reached, the Mediator shall prepare and distribute a nonbinding Mediation
statement under Section 5.95.050(f). The Mediator shall send the Mediation
statement to each party's address of record via first-class mail, postage prepaid.
(d) Mandatory Participation. Every party to a Mediation is affirmatively obligated to participate
in such Mediation in Good Faith until the Mediator determines the Mediation has
concluded.
(1) Definition. For purposes of this Section, Good Faith participation includes by
reference the definition described in Section 5.95.030 and also means the mutual
obligation of the Landlord and Tenant to meet on each occasion when notified of
Mediation proceedings, provide relevant information, exchange proposals, timely
consider and respond to proposals by opposite parties, and engage in meaningful
discussion on the subject of proposed Rent increases and issues related to the
Rent increase.
(2) Failure to participate in Good Faith.
(A) No Rent increase will be effective unless or until the Landlord of the
Dwelling Unit complies with the provisions of this Chapter by participating
in Good Faith as described in Section 5.95.030 and 5.95.050 throughout
the entirety of a Mediation process.
(B) If a Tenant fails to participate in Good Faith, the Mediator at his or her
discretion may determine that the Tenant has withdrawn their request for
Mediation service and conclude the Mediation process, allowing any Rent
increase to be implemented in accordance with the notice requirements
identified in California Civil Code section 827.
(3) Finding of a failure to participate in Good Faith.
(A) A Mediator or party to the Mediation process may request that the CDA
Director investigate a claim of failure to participate in Good Faith by another
party. The CDA Director shall be responsible for investigating allegations
of a lack of Good Faith participation by any party.
(B) Any determination that a party has failed to participate in Good Faith in a
proceeding under this Chapter shall only be made after a fair hearing by a
hearing officer appointed by the CDA Director and the rendition of factual
findings supported by the record. All parties to such hearing must receive
written notice of the hearing at least five business days prior to the hearing
date. Following such a hearing, the CDA Director shall give prompt notice
of the determination by first-class mail, postage prepaid, to the affected
party. Additional hearing procedures, including procedures for appeals (if
any), may be specified in the Guidelines.
(e) Mediation Agreements.
(1) Any agreement reached by the parties in Mediation must:
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(A) Be made in writing and signed by the parties;
(B) State the specific terms of the Mediation agreement including the duration
and conditions of the agreement;
(C) State the effective date of any agreed-upon Rent increase and stipulate to
the adequacy of notice for any Rent increase in accordance with California
Civil Code section 827;
(D) Be legally enforceable against the parties to the agreement;
(E) Provide that the agreement may be enforced via civil action by any party
and by the County or its designee as third-party beneficiaries; and
(F) Provide that any agent or representative signing a Mediation agreement on
behalf of other persons shall be responsible for promptly providing a copy
of the agreement to the parties they represent.
(2) A Tenant bound by a Mediation agreement may not request further Mediation
concerning any Rent increase covering the same time period included in the
Mediation agreement but may request Mediation concerning an additional Rent
Increase that is first noticed or occurs after the Mediation agreement is signed by
both parties.
(f) Mediation Statements. If a Mediation service does not result in a Mediation agreement,
then the designated Mediator shall produce a nonbinding Mediation statement. The
Guidelines shall include form Mediation agreements and Mediation statements that
include, without limitation, the following information:
(1) The name of each party that appeared for and participated in Good Faith in the
Mediation service; and
(2) A concise summary of the dispute including the perspectives of each party that
appeared for and participated in Good Faith in the Mediation service.
Section: 5.95.060 Anti-harassment and other prohibited activities.
(a) No Landlord may do any of the following in bad faith, with ulterior motive, or without honest
intent:
(1) Interrupt, fail to provide, or threaten to interrupt or fail to provide any Housing
Service under a lease or rental agreement, including but not limited to utility
services and other amenities and services agreed to by contract;
(2) Fail to perform repairs or maintenance required by contract or by State, or County
housing, health, or safety laws;
(3) Fail to exercise due diligence to complete repairs and maintenance once
undertaken, including the failure to follow industry-appropriate safety standards
and protocols;
(4) Abuse or otherwise improperly use Landlord's right to access the property;
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(5) Remove personal property of the Tenant(s) from the Dwelling Unit;
(6) Influence or attempt to influence the Tenant(s) to vacate the unit by means of fraud,
intimidation, or coercion (including but not limited to threats based on immigration
status in violation of California Civil Code section 1940.3);
(7) Offer payment or any other consideration, in return for the Tenant(s) vacating the
Dwelling Unit, more often than once every six months;
(8) Threaten the Tenant(s) by word or gesture with physical harm;
(9) Interfere with the Tenant(s) right to quiet use and enjoyment of the Dwelling Unit;
(10) Refuse to accept or acknowledge receipt of lawful Rent from the Tenant(s);
(11) Interfere with the Tenant(s) right to privacy;
(12) Request Information that violates the Tenant(s) right to privacy;
(13) Other repeated acts or omissions of such significance as to substantially interfere
with or disturb the Tenant(s) comfort, repose, peace, or quiet enjoyment, and that
cause, are likely to cause, or are intended to cause the Tenant(s) to vacate the
Dwelling Unit; or
(14) Retaliate against the Tenant(s) for the Tenant(s) exercise of rights under this
Chapter or state or federal law.
(b) Nothing in this Section 5.95.060 prohibits the lawful eviction of a Tenant in accordance
with California Civil Code section 1946.1 or by any other appropriate legal means.
Section: 5.95.070 Civil remedies.
(a) Injunctive relief. Any aggrieved person may enforce the provisions of this Chapter by
means of a civil injunctive action. Any person who commits, or proposes to commit, an act
in violation of this Chapter may be enjoined therefrom by any court of competent
jurisdiction. An action for injunction under this section may be brought by any aggrieved
person, by county counsel, the district attorney, or by any person or entity which will fairly
and adequately represent the interests of the protected class.
(b) Civil Liability. Any person who violates any of the provisions of this Chapter or who aids in
the violation of any provisions of this Chapter is liable for, and the court must award to the
individual whose rights are violated, three times the amount of special and general
damages. The court may award in addition thereto not less than two hundred dollars
($200.00) but not more than four hundred dollars ($400.00), together with attorney's fees,
costs of action, and punitive damages. Civil actions filed pursuant to this section must be
filed within one year of the events giving rise to the alleged cause of action.
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Section: 5.95.080 Notice of Tenant rights.
(a) Landlords must provide to each Tenant a notice of Tenant rights under this Chapter that
describes the Mediation service and how to request service; a form for providing such
notice may be issued in the Guidelines.
(b) Landlords must provide to Tenants the notice of Tenant rights under Section 5.95.080(a)
in the following circumstances:
(1) Within 30 calendar days of enactment of this Chapter;
(2) When entering a lease or rental agreement;
(3) When renewing a lease or rental agreement;
(4) When providing notice of a Rent increase; and
(5) At such times as required by the County, which may include, but is not limited to,
when this Chapter is significantly amended.
(c) All notices provided under this Section shall be provided in English, Spanish and
Vietnamese, in the translated form made available by the County. If the Tenant's rental
agreement was negotiated in another language, the Landlord is obligated to provide an
accurate translation of the notification in that other language as well. Translation services
for other documents or Mediations in languages other than English shall be made
available to persons requesting such services subject to the County's ability to provide
such services. In the event that the County is unable to provide such services, parties who
do not speak or are not comfortable with English must provide their own translators. To
participate in Mediation proceedings, the translators will be required to take an oath that
they are fluent in both English and the relevant foreign language and that they will fully
and to the best of their ability translate the proceedings.
(d) Failure to comply with the notice provisions described in this Chapter shall render any
rental increase notice invalid and unenforceable. The failure to comply with the notice
provisions will be cured only after the proper written notice of Tenant's Rights, along with
a new rental increase notice, has been properly served on the tenant.
Section: 5.95.090 Severability.
The provisions of this Chapter are declared to be severable. If for any reason, any section,
paragraph, clause, or phrase of this Chapter or the application thereof to any person, entity, or
circumstance is held to be invalid or unconstitutional, such invalidity or unconstitutionality shall
not affect the validity or constitutionality of the remaining sections, paragraphs, clauses or
phrases.