Edwards
Edwards v. Marin Park, Inc.
Opinion
Lead Opinion
Berzon, J.
In this appeal we consider whether a plaintiff may be sanctioned for declining the opportunity to amend her complaint. We answer in the negative. We also address the pleading standard for discrimination claims under the Fair Housing Act, 42 U.S.C. § 3601 et seq.
I. BACKGROUND
Since 1992, Priscilla Edwards has lived in a mobile home 2 in the Marin Park *1060 development in Greenbrae, California. See generally Hacienda Valley Mobile Estates v. City of Morgan Hill, 353 F.3d 651 (9th Cir.2003) (describing relationship of a mobile home park to a tenant-homeowner). Edwards alleges — accurately, we assume at this stage of the litigation — that the management of the park sent her unjustified, harassing pre-eviction notices in order to drive her from her tenancy. The notices, which the parties call “7 Day Legal Notices,” were first sent on January 27 and January 30, 1999. These missives apparently notified Edwards that her home was not in compliance with various provisions of California’s Mobilehome Residency Law, Cal. Civil Code ch. 2.5. 3 On February 2 and April 2, 1999, Edwards wrote the Park’s management, describing the two notices as “fraudulent, malicious, oppressive, willful and…