City of Petaluma files motion to dismiss mobile home lawsuit

The city of Petaluma has filed a motion to dismiss a lawsuit brought by the owners of two local mobile home parks who claim the city is infringing on their constitutional rights.

The motion to dismiss, filed Dec. 8 with the U.S. District Court’s Northern District, asks the court to toss out the suit brought by the owners of Youngstown and Little Woods mobile home parks, both located in Petaluma and the sites of recurring clashes between park owners and residents, as well as between the owners and city government.

“Plaintiffs have utterly failed to invoke this Court’s subject matter jurisdiction, due to lack of standing and ripeness, and fail to allege facts that plausibly state a claim,” states the city’s motion to dismiss.

In the original suit, filed Oct. 10 by the owners of Youngstown Mobile Home Park and Little Woods Mobile Villa, the plaintiffs made four claims that the city is violating their constitutional rights, of which three point to violations of the takings clause and the fourth to violations of a contractual clause in the U.S. Constitution.

In their suit, the owners claim Petaluma has violated their property rights because the city’s pre-closure requirements prohibit them from closing their parks and compels the owners to operate at a loss.

They also argue that the city’s requirement to pay the in-place value of the residents’ homes, should the parks close, is unconstitutional and doesn’t necessitate a public interest.

The plaintiffs further claim the city is violating the “takings clause” by compelling owners to operate without compensation and with no “economically viable or beneficial use of their lands,” according to their lawsuit.

Last, they claim that the city has weakened the strength of contractual agreements between residents and park owners.

In its motion to dismiss, the city states that claims made by the owners of Youngstown and Little Woods alleging that the city has taken their property rights have not come to fruition.

“They have yet to commence the process set forth in State and City law necessary to close or convert their parks, including filing of a relocation impact report with the City,” the motion states.

The city argues that owners lack standing to challenge a California law upheld by the city, where owners must pay the in-place value of a resident’s mobile home if replacement housing isn’t available.

Park owners “have not pleaded any facts to show they have been injured, either by the City or any other person or entity,” the motion states.

Because owners haven’t attempted to close their parks and haven’t shown facts that they’ve been injured, it’s unlikely the defendant can be remedied by a favorable court decision, the motion states.

The legal dispute comes amid an ongoing saga involving the two mobile home parks and their paying residents after the city tightened rules in July intended to protect all mobile home park residents through its mobile home rent stabilization program. The city also passed a senior overlay district in October designed to maintain the senior-only status of parks with that preexisting designation.

Residents at both Youngstown, a seniors-only park on N. McDowell Boulevard, and Little Woods, an all-ages park on Lakeville Highway with many Spanish-speaking residents, have faced threats of closure and high rent increases proposed by park owners that began just before the mobile home stabilization program went into effect last summer.

As a result of the proposed high rent increases, residents at both parks are scheduled for arbitration proceedings in January, which are required to determine whether the rent increases are justified to cover owners’ expenses.

As part of the city’s recently enacted mobile home regulations, rent increases at mobile home parks within city limits cannot exceed 70% of the Bay Area Consumer Price Index or CPI – a measure of the average change for the cost of goods and services – or 4%, whichever is lower. Currently, rent at mobile home parks cannot increase more than 2.9% per year.

Youngstown is scheduled for arbitration on Jan. 17 and 18, and Little Woods is scheduled for arbitration on Jan. 24 and 25.

You can reach Staff Writer Jennifer Sawhney at 707-521-5346 or jennifer.sawhney@pressdemocrat.com. On X/Twitter @sawhney_media.