Thursday, March 14, 2019

Strong Measures Against Tenant Harassment in San Francisco and Oakland

In November 2008, San Francisco voters approved Proposition M to amend the City's Rent Ordinance (S.F. Admin. Code, sec. 37.1 et seq.) The proposition modified the definition of housing services to include the "quiet enjoyment of the premises, without harassment by the landlord as provided in Section 10B." Section 37.10B was expanded to include 15 prohibited acts of harassment and to allow tenants to file a petition with the Rent Board for any conduct violating this Section and request a rent reduction.

Larson et al challenged these modifications in a civil law suit alleging that the expanded definition of a decrease in housing services violated the judicial powers clause of the Cal. Const. art. VI, sec. 1) and infringed on free speech rights, and that the additional mandatory, tenant-only cost and attorney fees provision violated equal protection rights.

The court struck the words "with ulterior motive or without honest intent" in the beginning phrase of the ordinance, upheld the decrease in housing services definition, and invalidated the cost and attorney fee provision. The plaintiff appealed the adverse part of the ruling. Pursuant to the appeal, the court ruled that if harassment was found under 37.01B(a)(4) through (15), that the Rent Board could not order rent reductions since, to do so, would impinge on the judicial power of the courts and allow the Rent Board to award damages for emotional distress. The court also struck 37.10B(a)(7) and 37.10B(c)(6).

In November 2014, Oakland's City Council passed a Tenant Protection Ordinance, in part, due to the "imbalance of bargaining power between landlords and tenants, which has resulted in many tenants, especially those not in rent controlled units, being unwilling or unable to assert their legal rights, which is detrimental to the health, safety, and general welfare of Oakland because the stability, security and quality of housing opportunities are reduced." The Rent Board requires landlords to issue a RAP (rental assistance program) notice to new tenants of rent-controlled residences and a TPO (tenant protection ordinance) notice is also supposed to be posted in the common area of residential rental units.

In both jurisdictions, should a tenant allege harassment by the landlord, their remedy is in civil court. The rent boards do not have the authority to decide a harassment issue but they can -- and do - define tenant harassment through their municipal code. Below is a cross-comparison of the Oakland and San Francisco tenant harassment ordinances. And, while certain sections were struck down by the courts in San Francisco, Oakland's similar wording has not yet faced a challenge, at least to this writer's knowledge.


OAKLAND
SAN FRANCISCO
TPO applies to all rental units where there is a lease agreement except nonprofit owned rental housing, rental units in a hospital, skilled nursing facility, or health facility, rental unit in a residential property that is a triplex and where one of the units is occupied by the owner, a rental unit in a newly constructed building

No owner or owner’s agent, contractor, subcontractor, or employee shall do any of the following in BAD FAITH
No landlord, and no agent, contractor, subcontractor, or employee of the landlord shall do any of the following in BAD FAITH with ulterior motive or without honest intent
Fail to perform repairs or threaten to do so
Fail to perform repairs and maintenance required by contract and/or law
Fail to exercise due diligence in completing repairs and maintenance
Fail to exercise due diligence in completing repairs and maintenance
Abuse the owner’s right of access into a rental housing unit
Abuse the owner’s right of access into a rental housing unit
Remove tenant’s personal property, furnishings, or other items without the prior written consent of the tenant unless when done pursuant to Cal. Civ. Code sec. 1980 et seq.

Influence or attempt to influence a tenant to vacate rental housing through fraud, intimidation, or coercion which includes threatening to report a tenant to the U.S. Immigration and Customs Enforcement
Influence or attempt to influence a tenant to vacate rental housing through fraud, intimidation, or coercion
Offer payments to a tenant to vacate more than once in six (6) months after tenant has notified the owner in writing about their desire not to receive further offers of payment to vacate
Offer payments to a tenant to vacate after tenant has notified the owner in writing that they no longer wish to receive offers of payments to vacate. [This clause was stricken pursuant to Larson v. City and Co. of San Francisco, (2011) 192 Cal. App. 4th 1263.]
Attempt to coerce a tenant to vacate with offer(s) of payments to vacate which are accompanied by threats or intimidation
Attempt to coerce a tenant to vacate with offer(s) of payments to vacate which are accompanied by threats or intimidation
Threaten the tenant, by word or gesture, with physical harm
Threaten the tenant, by word or gesture, with physical harm
Substantially and directly interfere with a tenant’s right to quiet use and enjoyment of the rental unit
Interfere with a tenant’s right to quiet use and enjoyment of the rental unit pursuant to California law
Refuse to accept or acknowledge receipt of a tenant’s lawful rent payment (with one exception)
Refuse to accept or acknowledge receipt of a tenant’s lawful rent payment
Refuse to cash a rent check for over 30-days unless a written receipt for payment has been provided to the tenant (with an exception)
Refuse to cash a rent check for over 30-days
Interfere with a tenant’s right to privacy
Interfere with a tenant’s right to privacy
Request information that violates a tenant’s right to privacy (see exceptions)
Request information that violates a tenant’s right to privacy (see exceptions)
Other repeated acts or omissions of such significance as to substantially interfere with or disturb the comfort, repose, peace or quiet of any person lawfully entitled to occupancy of such dwelling unit and that cause, or are likely to cause, or are intended to cause a tenant to vacate the rental unit or waive any rights related to that unit
Other repeated acts or omissions of such significance as to substantially interfere with or disturb the comfort, repose, peace or quiet of any person lawfully entitled to occupancy of such dwelling unit and that cause, or are likely to cause, or are intended to cause a tenant to vacate the rental unit or waive any rights related to that unit
Remove a housing service for the purpose of causing a tenant to vacate the rental unit such as a parking space or garage
Interrupt, terminate or fail to provide housing services required by contract or law

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