Ventura Mobilehome Communities Owners Association, an Unincorporated Association v. City of San Buenaventura

Plaintiff-Appellant, Ventura Mobile Home Communities Owners Association, contends the district court (1) miscalculated the date on which its claims brought under 42 U.S.C. § 1983 accrued and improperly applied the limitations period, (2) erroneously prevented it from asserting an “as applied” takings challenge, (3) erroneously found the Association had not properly exhausted the remedies provided by state law so that its federal claims were not ripe, and (4) erred in not considering its argument that the city ordinance is preempted by state law. We affirm the district court’s dismissal of Appellant’s federal claims, but remand for entry of a judgment of dismissal without prejudice on Appellant’s state law claims.

FACTS

The City of Buenaventura (“the City”) first adopted its Mobile Home Park Rent Stabilization Ordinance (“the Ordinance”) in 1981. Noting “the lack of alternative homesites for mobile home residents” and a “virtual monopoly ... in the rental of mobile home park spaces,” the City imposed a rent control structure for the claimed purpose of protecting mobile home residents from unreasonable rent increases.

The ordinance provided that space rents in mobile home parks…