Manufactured Home Communities Inc. v. City of San Jose

Manufactured Home Communities, Inc. and MHC Operating Limited Partnership (collectively MHC) sued the City of San Jose challenging the City’s Mobilehome Rent Ordinance as unconstitutional. MHC also sued four individual tenants of the MHC mobilehome park: Enis Rice, Gary DeWet, Martin Vancil, and Marsha Skratt (collectively Individual Defendants). MHC argued that the Individual Defendants are not eligible for rent control under California state law and are, thus, in violation of the City’s Ordinance and California state law for refusing to pay increased rent.

MHC appeals the district court’s dismissal of MHC’s complaint for various jurisdictional and res judicata problems. We affirm the district court’s decision on the basis of res judicata, untimeliness, failure to state a federal question, lack of supplemental jurisdiction, and California’s statute of limitations. Although it does not affect the outcome of this case, we reverse the district court’s holding on the Rooker-Feldman doctrine. We reverse and remand the matter of attorneys’ fees.

Jurisdiction and Standard of Review

The district court dismissed several of MHC’s claims for lack of subject matter jurisdiction under the…