Garcia v. Anthony

211 Cal. App. 3d 467, 259 Cal. Rptr. 393, 1989 Cal. App. LEXIS 597
CourtCalifornia Court of Appeal
DecidedJune 12, 1989
DocketNo. H004064
StatusPublished
Cited by1 cases

This text of 211 Cal. App. 3d 467 (Garcia v. Anthony) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Garcia v. Anthony, 211 Cal. App. 3d 467, 259 Cal. Rptr. 393, 1989 Cal. App. LEXIS 597 (Cal. Ct. App. 1989).

Opinion

Opinion

AGLIANO, P. J.

Introduction

By enacting the Relocation Assistance Act, the Legislature has provided that a public entity which acquires real property for public use must supply relocation assistance to any person, business, or farm operation displaced as a result of the acquisition. (Gov. Code, § 7260 et seq.)1 A “displaced” person includes one whose right of possession to real property arose after the date of the public entity’s acquisition of such property but who had no notice of the acquisition. (§ 7260, subd. (c)(1).) The act authorizes advisory assistance (§ 7261), moving expenses (§ 7262), cash payments to displaced dwelling owners (§ 7263), cash payments to certain lessees to assist them in obtaining comparable replacement housing (§ 7264), and “last resort housing” which the public entity is to itself provide where comparable replacement housing is otherwise unavailable (§ 7264.5).

Plaintiffs2 appeal to resolve which relocation benefits they are eligible for. Originally, they were denied all assistance; on review, the California Relo[470]*470cation Appeals Board (Board) found plaintiffs were displaced persons and ordered moving expenses; on mandamus, the superior court ordered moving expenses and advisory assistance only. We will reverse, holding plaintiffs entitled to be considered for last resort housing as well.

We initially point out that this appeal by plaintiffs focuses primarily upon the benefits to which the plaintiffs, as displaced persons within the meaning of the statute, may be entitled. We, as did the trial court, have questions whether plaintiffs qualify as displaced persons in the first place. That issue, however, is precluded by the posture of the case before us and the findings and conclusions reached below from which no appeal has been taken.

Facts

On June 13, 1974, the state purchased Wilder Ranch, a tract of agricultural land north of Santa Cruz, contemplating later development and use of the property as a recreational park. Pending development, the state leased the land to Pfyffer Brothers Ranch. On June 15, 1982, the lease was assigned to P. Bargiacchi and Son (Bargiacchi).

The lease provided: “8. Lessee agrees to use the leased premises for the production of vegetable crops and for no other purposes. . . . [If] 12. Lessee shall not, without previous consent in writing of State, sublet the Premises in whole or in part, nor assign this lease or any interest herein. . . . [fl] 28. It is understood and agreed that the improvements on the subject property belong to the Lessee and at termination of this lease, Lessee may remove the same within 60 days of said termination. If the improvements are not removed within said 60-day period, title thereto shall revert to the State.” On January 1, 1985, a new lease was executed between the state and Bargiacchi containing similar provisions.

The improvements referred to in each lease were six residential units. Beginning in September 1982, plaintiffs leased these units from Bargiacchi under 30-day agreements. Plaintiffs were not employed to assist in “the production of vegetable crops” and Bargiacchi did not obtain prior written consent from the state to sublet.

Bargiacchi informed the state in October 1985 that nonagricultural workers were occupying the residential buildings. On March 3, 1986, the state informed Bargiacchi he was in violation of the lease. Thereafter, Bargiacchi brought unlawful detainer actions against plaintiffs. Meanwhile, as of November 20, 1985, the Office of Real Estate Services of the Department of General Services, on behalf of parks and recreation officials, began considering the purchase of the structures occupied by plaintiffs. During the negoti[471]*471ations the parties to the January 1985 lease drafted a first amendment to lease, dated February 1, 1986. In this amendment, which would have taken effect on August 1, 1986, the three acres upon which the residential structures stood would have been deleted from the Bargiacchi leasehold in exchange for reduced rent. The Department of General Services, the state agency with final power of approval of state leases and their amendments, never executed the amendment.

Plaintiffs applied for and were denied all relocation assistance following their receipt of notices terminating their tenancies of buildings located on state-owned land. They then sought administrative review before the Board. Following the administrative hearing, but before the Board issued its decision, plaintiffs also filed an action to enjoin the unlawful detainer actions pending against them in municipal court. (Garcia et al. v. Anthony et al. (Super.Ct. Santa Cruz County, No. 100990).) Since the instant action encompassed essentially the same issues raised in the unlawful detainer action, the parties stipulated to consolidate the two actions and to maintain the status quo pending resolution of the mandamus action.

The Board determined that plaintiffs were “post acquisition tenants who had no knowledge the land was state owned, as defined in Government Code Section 7260(c)(1)” and decided that they were entitled to moving expenses only. Plaintiffs challenged the limitation of benefits by petition for writ of mandate in the Santa Cruz Superior Court seeking a determination that their status as displaced persons qualified them to be considered for additional benefits including last resort housing. While expressing doubt as to the Board’s conclusion that plaintiffs were displaced persons within the meaning of the statute, the court, noting defendants’3 concession as to that question, and deeming it equitable to do so, agreed with the Board’s conclusion as to plaintiffs’ status. The court denied, however, plaintiffs’ claim to consideration for a money payment or last resort housing, finding instead that plaintiffs’ entitlements were limited to moving expenses and advisory assistance. The court also dissolved the stay of prosecution of the unlawful detainer actions, effective October 1, 1987. Plaintiffs vacated the property on October 31, 1987.

Discussion

As noted above, the Relocation Assistance Act facilitates the resettlement of residents of property who are displaced by a public entity’s acquisition of the property for public use. The Department of Housing and Community [472]*472Development has been authorized to adopt guidelines to implement the act.4 “The [Relocation Assistance] Act and the Guidelines are intended for the benefit of displaced persons, to ensure that such persons receive fair and equitable treatment and do not suffer disproportionate injuries as the result of programs designed for the benefit of the public as a whole. The Act, Guidelines and all applicable regulations on which determinations are based shall be construed to effect this intent.” (Cal. Code Regs., tit. 25, § 6002, subd. (e), italics added.) Further, the provisions of the Relocation Assistance Act are to be construed as a whole. (McKeon v. Hastings College (1986) 185 Cal.App.3d 877, 896 [230 Cal.Rptr. 176], and cases cited therein.)

Pursuant to the act, after a tenant is designated a displaced person, that tenant is entitled to advisory assistance (§ 7261)5 and moving expenses (§ 7262).6 Noteworthy is the provision that advisory assistance includes [473]

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Bluebook (online)
211 Cal. App. 3d 467, 259 Cal. Rptr. 393, 1989 Cal. App. LEXIS 597, Counsel Stack Legal Research, https://law.counselstack.com/opinion/garcia-v-anthony-calctapp-1989.