Little Woods Mobile Villa LLC v. City of Petaluma

I. BACKGROUND

17 Plaintiffs are two limited liability companies that own mobile home parks in 18 Petaluma. Compl. (dkt. 1) ¶¶ 4–5. This case involves claims that the City of Petaluma 19 (the “City”) has regulated mobile home parks in a way that violates Plaintiffs’ 20 constitutional rights under the U.S. Constitution’s Takings Clause—under a per se physical 21 takings theory, a regulatory takings theory, and a Nollan/Dolan exaction theory—as well 22 as the Contracts Clause. The challenged laws are a City of Petaluma (the “City”) rent 23 control ordinance and a legal regime that makes it difficult for mobile home park owners 24 to close their parks or convert them to other uses. 25 Some of Plaintiffs’ claims are directed at only one of these laws—the rent control 26 ordinance, the closure regulations, or—for the Contracts Clause claim—a specific aspect 27 of a state law that imposes conditions on mobile home closures. But the core of Plaintiffs’ takings theory is about how the laws act together. That is, Plaintiffs allege that it is economically infeasible to continue operating their parks because the City’s rent-control ordinance prevents Plaintiffs from…