Carter

Respondent Lauren Carter sued her landlord, appellant Jerry Cohen, alleging that her rent payments contravened the Los Angeles Rent Stabilization Ordinance (L.A. Mun. Code, § 151.00 et seq.) (RSO). After a jury found that Carter was entitled to damages of $11,590 for overpayment of rent, the trial court awarded her $25,575 in attorney fees under a fee-shifting provision of the RSO. Cohen challenges the award of damages on the ground that the rental agreement was unlawful; in addition, he maintains that the fee award was improper because Carter’s damages were recoverable in a limited civil case. We affirm the judgment in its entirety.

RELEVANT FACTUAL AND PROCEDURAL HISTORY

In 2002, Carter entered into a lease agreement with Ree Whitford regarding a guesthouse in North Hollywood. The guesthouse contained two rooms with a kitchen area, and was detached from a house on the same property. The guesthouse had been constructed without building permits, and was not registered under the RSO. From 2002 to 2004, Carter paid Whitford $890 per month in rent.

In September 2004, Cohen, an attorney, bought the house and its guesthouse from Whitford, and increased Carter’s monthly rent…