Sylvia Landfield Trust v. City of Los Angeles, No. 11-55904 (9th Cir. 2013)
Annotate this CasePlaintiffs, four landlords, challenged the constitutionality of the City's Rent Escrow Account Program (REAP). The Housing Department places property into REAP when a landlord fails to repair habitability violations and tenants pay a reduced rent. The court concluded that placing plaintiffs' property into REAP did not violate plaintiffs' substantive due process rights where REAP served legitimate governmental goals and was rationally related to a legitimate governmental purpose; plaintiffs' procedural challenge could not support an as-applied substantive due process claim; and denial of leave to amend the complaint was not an abuse of discretion. Accordingly, the court affirmed the district court's dismissal of the complaint.
Court Description: Civil Rights. The panel affirmed the district court’s Fed. R. Civ. P. 12(b)(6) dismissal of plaintiffs’ complaint challenging the constitutionality of the City of Los Angeles’s Rent Escrow Account Program. The Los Angeles Rent Escrow Account Program (REAP) is an administrative program codified in the Los Angeles Municipal Code which authorizes the Los Angeles Housing Department to place property into REAP when a landlord fails to repair habitability violations. Plaintiffs, four landlords whose separate apartment buildings were placed into REAP by the City, alleged that REAP, as applied to them, violated their substantive due process rights. The panel held that: (1) REAP was rationally related to the legitimate governmental interests of repairing and preventing substandard housing; (2) REAP did not violate plaintiffs’ substantive due process rights; and (3) plaintiffs’ procedural challenges failed to support an as-applied substantive due process claim because none of the allegations plausibly suggested that REAP was arbitrarily and unreasonably applied to any of the plaintiffs, or that the placement of plaintiffs’ properties into REAP rose to a level that shocked the conscience.
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