Howard Iten v. County of Los Angeles

CourtDistrict Court, C.D. California
DecidedSeptember 15, 2021
Docket2:21-cv-00486
StatusUnknown

This text of Howard Iten v. County of Los Angeles (Howard Iten v. County of Los Angeles) is published on Counsel Stack Legal Research, covering District Court, C.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Howard Iten v. County of Los Angeles, (C.D. Cal. 2021).

Opinion

1 2 O 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 11 HOWARD ITEN, ) Case No. CV 21-00486 DDP (JEMx) ) 12 Plaintiff, ) ) 13 v. ) ORDER GRANTING DEFENDANT’S MOTION ) TO DISMISS [15][16] 14 COUNTY OF LOS ANGELES, ) ) 15 Defendant. ) ___________________________ ) 16 17 Presently before the court is Defendant County of Los Angeles 18 (“the County”)’s Motion to Dismiss. Having considered the 19 submissions of the parties and heard oral argument, the court 20 grants the motion and adopts the following Order. 21 I. Background 22 Plaintiff Howard Iten is part-owner of a commercially zoned 23 property in the County of Los Angeles. (Complaint ¶ 8.) Beginning 24 in March 2020, the County imposed a moratorium on commercial tenant 25 evictions for nonpayment of rent related to the COVID-19 global 26 pandemic (“the Moratorium”).1 (Id. ¶ 18(I); Declaration of Kathryn 27 28 1 The term “tenant” excludes commercial tenants “that are 1 D. Valois, Ex. A.) The Moratorium prohibits the eviction of a 2 commercial tenant for nonpayment of rent or late fees “if the 3 Tenant demonstrates an inability to pay rent and/or such related 4 charges due to Financial Impacts related to COVID-19 . . . and the 5 Tenant has provided notice to the Landlord within seven (7) days 6 after the date that rent /and or such related charges were due, 7 unless extenuating circumstances exist, that the Tenant is unable 8 to pay.” (Moratorium § V(A)(1).) Commercial tenants with fewer 9 than ten employees may satisfy these notice requirements with a 10 self-certification. (Moratorium § V(B)(2).) Such tenants have 11 twelve months from the expiration of the Moratorium, currently 12 scheduled for September 30, 2021, to repay any unpaid rent. 13 (Moratorium § V(C)(2)(a).) The Moratorium also prohibits 14 harassment of tenants, including any attempt to evict a tenant 15 “based upon facts which the Landlord has no reasonable cause to 16 believe to be true or upon a legal theory which is untenable under 17 the facts known to the Landlord.”2 (Moratorium § VIII(I).) 18 Failure to comply with the Moratorium may result in civil 19 penalties, including fines of up to $5,000 per day, and is 20 punishable as a misdemeanor. (Moratorium § X(A),(B).) 21 Plaintiff has “had a number of issues” with his commercial 22 tenant over the past several years, including failure to pay rent 23 and unauthorized alterations to the property, resulting in building 24 code violations. (Compl. ¶ 23.) In April 2020, the tenant 25 informed Plaintiff that the tenant “is very adversely affected by 26 27 2 No Landlord is liable for harassment for pursuing eviction “unless and until the Tenant has obtained a favorable termination 28 of that action.” (Moratorium § VIII(I).) 1 Covid 19 and . . . will not be able to pay the rent.” (Id.) 2 Plaintiff’s tenant did not pay rent for the next several months. 3 (Id.) 4 The tenant’s lease expired at the end of August 2020. (Compl. 5 ¶ 24.) Notwithstanding the tenant’s nonpayment of rent and the 6 other “issues,” Plaintiff entered into a new, five-year lease with 7 the tenant, reasoning that so doing would increase the chances that 8 Plaintiff would recover past-due rent. (Id.) The new lease 9 requires the tenant to pay both base rent and $3,200 in past-due 10 rent every month. (Compl. ¶ 26.) Although the new lease went into 11 effect on September 1, 2020, the tenant has not made any rent 12 payments. (Compl. ¶ 28.) Sometime in October 2020, the tenant 13 conveyed to Plaintiff that “times are tough and [the tenant] will 14 not be able to pay the full amount on time.” (Id. ¶ 29.) 15 Plaintiff alleges that, but for the Moratorium, he would 16 immediately evict his tenant. (Compl. ¶ 31.) Plaintiff’s 17 Complaint brings a single cause of action, alleging that the 18 Moratorium’s ban on commercial evictions violates Plaintiff’s 19 rights under the Constitution’s Contracts Clause.3 The County now 20 moves to dismiss Plaintiff’s Complaint. 21 II. Legal Standard 22 A complaint will survive a motion to dismiss when it 23 “contain[s] sufficient factual matter, accepted as true, to state a 24 claim to relief that is plausible on its face.” Ashcroft v. Iqbal, 25 556 U.S. 662, 678 (2009)(quoting Bell Atl. Corp. v. Twombly, 550 26 U.S. 544, 570 (2007)). When considering a Rule 12(b)(6) motion, a 27 3“ No State shall . . . pass any . . . Law impairing the 28 Obligation of Contracts . . . .” U.S. Const. art. I, § 10, cl. 1. 1 court must “accept as true all allegations of material fact and 2 must construe those facts in the light most favorable to the 3 plaintiff.” Resnick v. Hayes, 213 F.3d 443, 447 (9th Cir. 2000). 4 Although a complaint need not include “detailed factual 5 allegations,” it must offer “more than an unadorned, 6 the-defendant-unlawfully-harmed-me accusation.” Iqbal,556 U.S. at 7 678. Conclusory allegations or allegations that are no more than a 8 statement of a legal conclusion “are not entitled to the assumption 9 of truth.” Id. at 679. In other words, a pleading that merely 10 offers “labels and conclusions,” a “formulaic recitation of the 11 elements,” or “naked assertions” will not be sufficient to state a 12 claim upon which relief can be granted. Id. at 678 (citations and 13 internal quotation marks omitted). 14 “When there are well-pleaded factual allegations, a court 15 should assume their veracity and then determine whether they 16 plausibly give rise to an entitlement of relief.” Iqbal,556 U.S. 17 at 679. Plaintiffs must allege “plausible grounds to infer” that 18 their claims rise “above the speculative level.” Twombly, 550 U.S. 19 at 555-56. “Determining whether a complaint states a plausible 20 claim for relief” is “a context-specific task that requires the 21 reviewing court to draw on its judicial experience and common 22 sense.” Iqbal, 556 U.S. at 679. 23 III. Discussion 24 The County contends that Plaintiff’s Complaint must be 25 dismissed because, under the facts alleged, the Moratorium did not 26 cause any injury to Plaintiff. (Motion at 19.) Although not 27 framed precisely as such, this argument presents a question of 28 1 standing.4 “Standing under Article III of the Constitution has 2 three basic elements: (1) an “injury in fact,” which is neither 3 conjectural nor hypothetical; (2) causation, such that a causal 4 connection between the alleged injury and offensive conduct is 5 established; and (3) redressability, or a likelihood that the 6 injury will be redressed by a favorable decision. Nat’l Fed’n of 7 the Blind of California v. Uber Techs., Inc., 103 F. Supp. 3d 1073, 8 1078 (N.D. Cal. 2015) (citing Lujan v. Defenders of Wildlife, 504 9 U.S. 555, 560–61 (1992)). If, as the County contends, the 10 Moratorium does not prevent Plaintiff from evicting his tenant, 11 then as a matter of course, the Moratorium cannot have caused 12 Plaintiff any injury. 13 The Moratorium only prohibits the eviction of a commercial 14 tenant if (1) “the Tenant demonstrates an inability to pay rent . . 15 . due to Financial Impacts related to COVID-19” and (2) “the Tenant 16 has provided notice to the Landlord within seven (7) days after the 17 date that rent [was] due,” unless (3) “extenuating circumstances 18 exist.” As alleged in the Complaint, Plaintiff’s tenant owed rent 19 under the current lease beginning on September 1, 2020. The tenant 20 did not, however, provide any notice to Plaintiff of inability to 21 pay until over a month later.

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Bluebook (online)
Howard Iten v. County of Los Angeles, Counsel Stack Legal Research, https://law.counselstack.com/opinion/howard-iten-v-county-of-los-angeles-cacd-2021.