Morgan

The City of Chino (city) appeals from a judgment awarding Beverly C. Morgan (Morgan) damages and granting her a writ of administrative mandamus based on the city council’s refusal to grant a rent increase to compensate Morgan for a capital improvement to the streets of her mobilehome park. The judgment was based on the trial court’s conclusion that the council was required by due process and its own rent control ordinance to permit a rent increase sufficient to allow Morgan to both recoup the cost of and earn a fair return on the capital improvement. We disagree with this legal conclusion and reverse the judgment in its entirety. Due process and the city’s rent control ordinance merely required the council to take the capital improvement into account when determining whether Morgan was earning a fair return on her investment in the park as a whole. The council properly applied that standard and rejected the requested rent increase because Morgan never provided the evidence necessary to calculate her overall rate of return.

Statement of Facts

1. Rent Control Ordinance

This case involves the Chino mobilehome park rent control ordinance, which was intended to “protect the…