Manufactured Home Communities, Inc. v. County of San Luis Obispo

The Constitution protects everyone, the poor, the wealthy, the weak, the powerful, the guilty and the innocent. This court has held its guarantees extend to lawyers (Cunningham v. Superior Court (1986) 177 Cal.App.3d. 336 [ 222 Cal.Rptr. 854 ]); dogs (more precisely their owners) (Phillips v. San Luis Obispo County Dept. etc. Regulation (1986) 183 Cal.App.3d 372 [ 228 Cal.Rptr. 101 ]); and even politicians (Beilenson v. Superior Court (1996) 44 Cal.App.4th 944 [ 52 Cal.Rptr.2d 357 ]). Here we add to our list—mobilehome park owners.

Plaintiffs Manufactured Home Communities, Inc., and MHC Operating Limited Partnership (MHC) appeal a judgment denying their petition for writ of administrative mandamus against defendants County of San Luis Obispo (County), the County Board of Supervisors (Supervisors), and the County of San Luis Obispo Mobilehome Rent Review Board (Board). MHC claims that the Board’s decision improperly prevented it from increasing the rent of its mobilehome park tenants.

We conclude, among other things, the proceeding violated standards of due process because the Board’s findings rested on testimony of tenants who were not subject to cross-examination. We…