Cal. Apartment Assn. v. City of Pasadena (2025)

Citation: Cal. Apartment Assn. v. City of Pasadena (2025)
Parent Document: Cal. Apartment Assn. v. City of Pasadena (2025)
Jurisdiction: California (state)
Effective Date: 2025-12-18
Original Source: https://www.courtlistener.com/opinion/10761039/cal-apartment-assn-v-city-of-pasadena/ ↗

Full Text

1,864 chars

55
treatment of [the] field of the setting of residential rental rates,
indicating the Legislature’s intent to fully occupy the field.” To
support this proposition, they rely on legislative history
indicating the Act was intended to “establish statewide
guidelines for any local regulation of rental rates for residential
accommodations. It would pre-empt more restrictive controls.”
(See Sen. Com. on Judiciary, Analysis of Sen. Bill No. 1257 (1995-
1996 Reg. Sess.) as introduced Apr. 4, 1995, p. 3.) However, this
legislative history does not amount to a clear statement of intent
to fully occupy the broad field of rent control such that no
“additional requirements” connected to rent control may be
imposed. (See American Financial Services Assn. v. City of
Oakland, supra, 34 Cal.4th at p. 1252, italics added.) Rather, it
merely provides that more “restrictive” controls will be
preempted, i.e., measures that contradict the provisions of the
Costa-Hawkins Act. (See Sen. Com. on Judiciary, Analysis of
Sen. Bill No. 1257, supra, p. 3.)
       The text of the Costa-Hawkins Act contains no express
statement of intent to fully occupy the broad field of rent control.
Nor has the Legislature impliedly manifested such intent.
(Chevron, supra, 15 Cal.5th at p. 142.) Rather, in the more
recent Tenant Protection Act of 2019 (Assem. Bill No. 1482, 2019-
2020 Reg. Sess.), the Legislature explicitly acknowledged local
governments’ authority to establish rent regulations that are
“otherwise consistent” with the Costa-Hawkins Act. (Civ. Code,
§ 1947.12, subd. (m)(2).) Likewise, in Action Apartment, supra,
41 Cal.4th at page 1245, which postdated the enactment of the
Costa-Hawkins Act, the California Supreme Court reaffirmed
that, so long as local measures or regulations do not conflict with
state law, “municipal governments [have] the authority to enact

Other Sections in This Document (114)

Full Text