BILL ANALYSIS
AB 2743
Page 1
Date of Hearing: May 4, 2010
ASSEMBLY COMMITTEE ON JUDICIARY
Mike Feuer, Chair
AB 2743 (Nava) - As Amended: April 28, 2010
As Proposed to Be Amended
SUBJECT : REAL PROPERTY: RENTALS: ANIMALS.
KEY ISSUE : SHOULD LANDLORDS BE PROHIBITED FROM IMPOSING
CONDITIONS ON OCCUPANCY OF REAL PROPERTY THAT MIGHT CAUSE ANY
ANIMAL ALLOWED ON THE PREMISES TO BE DEVOCALIZED OR DECLAWED?
FISCAL EFFECT : As currently in print this bill is keyed
non-fiscal.
SYNOPSIS
This bill, sponsored by the Paw Project, seeks to prohibit
landlords and other persons who own or manage real property from
imposing conditions on occupancy of the property that might
cause an animal that is allowed on the premises to be
devocalized or declawed. Under this comprehensively conceived
bill, landlords and property owners are broadly prohibited from
taking any actions that might put people in the untenable
position of having to choose between their housing
accommodations or paying a veterinarian to perform declawing or
devocalizing surgery on their pet cat or dog. The bill also
seeks to protect prospective tenants and occupants by broadly
prohibiting discrimination, preferential treatment, and
advertising of property available for occupancy based on certain
debarking or declawing considerations. These provisions only
apply when an animal in question is already allowed on the
premises; thus this bill does not apply if the landlord has a
no-pets policy, nor does it compel landlords to accept pets in
any case. This bill provides for a civil penalty of up to $2500
per animal for each violation that causes a pet to actually be
declawed or devocalized, and a civil penalty of not more than
$1000 for other lesser offenses that do not cause the actual
declawing or devocalization of an animal. This bill authorizes
an I.R.C section 501(c)(3) organization dedicated to the
protection of animals with standing to enforce this act, and as
an additional incentive for enforcement, to collect civil
penalties for violations that it successfully enforces. This
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bill is supported by numerous animal advocacy groups, in
addition to the California Apartment Association, and the
Western Center on Law and Poverty. It is opposed by the
nonprofit Animal Council, who oppose efforts to de-legitimize
elective veterinary procedures that are otherwise lawful
veterinary practice in California, and who also contend this
bill would cause more landlords to adopt no-pet policies, thus
reducing housing available to pet owners.
SUMMARY : Prohibits landlords from imposing conditions on
occupancy of real property that might cause an animal that is
allowed on the premises to be devocalized or declawed.
Specifically, this bill :
1)Defines "devocalizing" to mean performing, procuring, or
arranging for any non-therapeutic surgical procedure such as a
vocal cordectomy, to remove an animal's vocal chords or to
prevent the normal function of an animal's vocal chords.
2)Defines "declawing" to mean performing, procuring, or
arranging for any non-therapeutic surgical procedure, such as
an onychectomy, tendonectomy, or phalangectomy, to remove or
to prevent the normal function of an animal's claw or claws.
3)Prohibits a person or corporation that occupies, owns,
manages, or provides services in connection with any real
property, and that allows an animal on the premises, from
doing any of the following:
a) Advertise, through any means, the availability of real
property for occupancy in a manner designed to discourage
application for occupancy of that real property because the
applicant's animal has not been devocalized or dec1awed.
b) Refuse to allow the occupancy of any real property,
refuse to negotiate the occupancy of any real property, or
to otherwise make unavailable or deny to any other person
the occupancy of any real property because of that person's
refusal to devocalize or declaw any animal.
c) Require any tenant or occupant of real property to
devocalize or declaw any animal allowed on the premises.
d) Give preferential treatment in the terms of the right of
occupancy or the provision of services to another person
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because that person owns an animal that has been
devocalized or declawed.
e) Discriminate in the terms of occupancy or the provision
of services against another person because that person owns
an animal that has not been devocalized or declawed.
4)Establishes that, in addition to those harmed by violation of
this section, an I.R.C section 501(c)(3) organization
dedicated to the protection of animals has standing to enforce
this act.
5)Provides for a civil penalty of not more than $2500 per animal
for a violation of this act that causes the declawing or
devocalization of the animal, to be paid to the person whose
animal was declawed or devocalized or to a plaintiff IRC
section 501(c)(3) organization entitled to bring an action
under this act.
6)Provides that violation of this section that has not caused
the declawing or devocalizing of an animal shall result in a
civil penalty of not more than one thousand dollars ($1,000)
to be paid to the plaintiff.
7)Clarifies that nothing in this act shall prevent the inclusion
in an occupancy agreement of a provision that a present or
potential occupant may not declaw or devocalize an animal that
will be allowed on the premises.
8)Makes legislative findings and declarations.
EXISTING LAW :
1)Prohibits any person from performing, or otherwise procuring
or arranging for the performance of, surgical claw removal,
declawing, onychectomy, or tendonectomy on any cat that is a
member of an exotic or native wild cat species, and from
otherwise altering such a cat's toes, claws, or paws to
prevent the normal function of the cat's toes, claws, or paws,
unless the procedure is performed solely for a therapeutic
purpose. Further provides that any person who violates this
prohibition is guilty of a misdemeanor punishable by
imprisonment in a county jail for a period not to exceed one
year, by a fine of ten thousand dollars ($10,000), or both.
(Penal Code Section 597.6.)
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2)Prohibits, generally, discrimination and related conduct with
respect to the rental or sale of housing accommodations on the
basis of a person's race, color, religion, sex, sexual
orientation, marital status, national origin, ancestry,
familial status, and other factors. (Gov. Code 12955.)
3)Authorizes corporations for the prevention of cruelty to
children or animals, or both, to be formed under the Nonprofit
Public Benefit Corporation Law, and allows any such
corporation, or any member or officer thereof, to prefer a
complaint against any person, before any court or magistrate
having jurisdiction, for the violation of any law relating to
or affecting children or animals, and may aid in the
prosecution of any such offender before such court or
magistrate. (Corporations Code Section 10401 and 10404.)
COMMENTS : This bill, sponsored by the Paw Project, seeks to
prohibit landlords and other persons who own or manage real
property from imposing conditions on occupancy of the property
that might cause an animal that is allowed on the premises to be
devocalized or declawed. Under this comprehensively conceived
bill, landlords and property owners are broadly prohibited from
taking any actions that might put people in the untenable
position of having to choose between their housing
accommodations or paying a veterinarian to perform declawing or
devocalizing surgery on their pet cat or dog. The bill also
seeks to protect prospective tenants and occupants by broadly
prohibiting discrimination, preferential treatment, and
advertising of property available for occupancy based on certain
debarking or declawing considerations.
Terminology; Reported Complications of Surgery. As used in this
bill, the terms "devocalized" and "declawed" refer to two
specific veterinary surgical procedures, the former primarily
performed on dogs, and the latter on cats. The author has
provided the following descriptions of the procedures and some
of the reported complications sometimes associated with them:
"Devocalization" (also known as debarking, bark
softening, ventriculo-cordectomy and vocal cordectomy)
is a surgical procedure applied to dogs and cats,
where tissue is removed from the animal's vocal cords
in order to permanently reduce the volume of their
vocalizations. Complications can include the airway
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becoming obstructed by scar tissue, breathing
difficulties, chronic coughing or gagging, an
increased risk of threats to physical safety and
stress because of an inability to ward of threats by
vocalizing.
"Declawing" or onychectomy, is an operation to
surgically remove an animal's claws by means of
amputating of all or part of the distal phalanx, or
end bones, of the animal's toes. Complications can
include anesthetic complications including death,
hemorrhage, and infection; chronic pain; lameness;
aggression; litter box avoidance; and an increased
tendency to bite after declawing.
Although surgical complications can be expected to vary from one
case to another, the author notes very simply in Section 1 of
the bill that "declawing and devocalizing have irreversible
effects on the animals that undergo these procedures."
Need for the bill. According to the author, this bill
essentially seeks to put an end to the problematic practice of
some landlords in California of imposing conditions on occupancy
of their property that may cause some prospective tenants or
occupants in turn to have their animals declawed or devocalized.
The author explains:
A search of rental listings throughout California
produces a number of properties with landlords and
managers requiring that potential owners will be
considered only with declawed cats or devocalized
dogs. Both of these practices can have unintended
consequences for property managers, physical
complications for animals, and emotional and financial
consequences for pet owners. It is unconscionable that
some prospective tenants are promised housing in
California conditioned upon the completion of surgical
procedures on their pets with potential complications
that are increasingly being viewed as inhumane and
outdated. AB 2743 will rectify this situation by
prohibiting this condition of tenancy.
As the author indicates in Section 1 of the bill, another reason
this legislation is needed is that declawing and devocalizing
"may have the unintended consequence of creating potential
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public health and safety concerns." For example, a devocalized
attack dog present on property that law enforcement officers may
legally enter to investigate a crime poses a special threat to
the safety of those officers because of its incapability to bark
or make its presence known.
Furthermore, the author contends that addressing this problem in
the area of landlord-tenant law is appropriate because "the
permanence of these surgical procedures contrasts with the
temporary nature of occupancy of real property owned by
another." Another way of conceptualizing this is that a cat's
claws, once removed, are gone forever-- potentially long after
that animal's owner has completed the fixed term of an occupancy
agreement that was the catalyst for the surgery in the first
place. As a policy matter, it appears the author wishes to
minimize instances of debarking and declawing procedures that
would not otherwise have occurred but for the pet owner acting
to meet actual or perceived conditions placed by a landlord or
property owner on property available for occupancy.
Scope of the bill, generally. On other occasions, the Committee
has encountered bills that appeared to apply in greater or
lesser scope than intended by the author because of a lack of
precise wording at necessary locations in the bill. That,
however, is not the case with this bill. The Committee has had
the opportunity to review the language of this bill while
working closely with the author to determine the scope of its
application, and concludes the author has carefully drafted this
bill with the intent that its provisions shall apply very
broadly to cover all manner of situations that may arise when
property is made available for occupancy.
The bill does not apply unless an animal is allowed on the
premises. This bill only applies when the landlord, manager, or
property owner, as defined, already allows an animal to be on
the premises before imposing any condition or taking any action
to have that animal declawed or devocalized. In other words,
this bill does not apply to any situation where the party making
the property available for occupancy specifically forbids an
animal on the premises. This bill does not infringe upon any
landlord's ability to implement a "no-pets" policy or forbid a
tenant or occupant from having an animal on the premises.
Once effective, the bill will apply to lease and occupancy
agreements already in existence, in addition to prospective
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occupancies. There is no language in this bill limiting its
application prospectively to occupancy of property commencing
after the date the bill becomes effective. Instead, once this
bill becomes effective it would seem to immediately apply to
prohibit landlords and property owners from imposing conditions
on existing tenants or occupants of property that might cause an
animal allowed on the premises to be declawed or devocalized.
Despite characterizations as a "landlord-tenant" bill, this bill
is intended to cover a broader range of situations. First, the
bill refers throughout only to "real property" because the
author intends the bill to apply to all real property--
commercial, residential, and mixed-use. Second, the bill does
not specifically use the term "landlord" because it is intended
to proscribe conduct not only by landlords, as that term is
generally defined, but by any "person or corporation that
occupies, owns, manages, or provides services in connection with
any real property." Nor does the bill refer only to "tenants"
because it is intended to protect owners of animals who are not
necessarily tenants in a legal landlord-tenant relationship. In
structuring the bill around "occupancy of real property," the
author intends to cover situations where one person essentially
leverages the right of occupancy or potential occupancy against
another person to have that person devocalize or declaw an
animal that is allowed on the premises. This could be within an
ordinary landlord-tenant relationship, but also is intended to
apply to landlords and occupants, tenants and subtenants, and
between roommates or co-occupants of real property. The author
has specifically contemplated all of these permutations and
drafted the bill to apply in all of these scenarios.
There is also no requirement that the tenant or occupant of the
real property be the true owner of an animal that is declawed or
devocalized in violation of this bill. The author has
contemplated situations where, for example, an occupant of the
property has agreed to temporarily take care of another person's
pet cat or dog where that animal is otherwise allowed to be on
the premises, but then is faced with a choice of having the
animal declawed or devocalized at the risk of losing the right
to occupancy. This scenario would still be covered by the
prohibition and liability provisions of the bill.
As proposed to be amended, this bill prohibits a slightly
broader range of conduct by landlords or property owners,
including situations where no express conditions on occupancy
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are made. The author has proposed to amend the bill to clarify
the scope of conduct that is prohibited by this bill by
replacing the narrower language of Section 1942.7(b)(3) of the
bill (page 3, lines 1 to 3) with slightly more general language
already contained in Sec. 1942.7(a) of the bill (page 2, lines
16 to 18.) The effect is that a narrower prohibition is
eliminated in favor of a broader, more general prohibition
having a similar objective, and two subdivisions of the bill are
now combined into one. Specifically, the proposed amendment
clarifies that no person or corporation that occupies, owns,
manages, or provides services in connection with real property
may require any tenant or occupant of real property to
devocalize or declaw any animal allowed on the premises. The
deleted language was somewhat narrower in scope because it
prohibited requiring another person to devocalize or declaw an
animal "as a condition of applying for occupancy, the right of
occupancy, or continued occupancy of any real property."
(italics added.) The proposed amendment is intended to cover a
broader range of situations where, for example, a landlord
intimidates an occupant but does not go so far as to expressly
condition the right of occupancy on completion of the declawing
procedure. It is thought that the new language might reduce
some questions that would potentially result in litigation, for
example: what was the intent of the landlord when he or she made
the demand for declawing? Did the landlord establish declawing
as a "condition" of occupancy?)
Violations subject to a $2500 civil penalty. As will be
discussed below, a violation of this particular prohibition is
considered a "major" offense because it necessarily results in
an animal undergoing a declawing or devocalizing procedure, and
is subject to the maximum civil penalty allowed by this bill-an
amount of up to $2500.
Violations subject to a $1000 civil penalty. The proposed
amendments do not change other types of conduct prohibited under
this bill that are considered "lesser" violations because they
do not result in the actual declawing or devocalizing of an
animal allowed on the premises. These lesser violations are
subject to a civil penalty not to exceed $1000 and include the
following:
1. "Advertising the availability of real property for occupancy
in a manner designed to discourage application for occupancy
because the applicant's animal has not been devocalized or
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declawed": The objective of this prohibition is to address the
problem of landlords running ads for their rental properties
that state a discriminatory preference for an occupant whose
animal is declawed or devocalized. The author and sponsor have
supplied the Committee with a number of examples of classified
ads for rental housing that state a preference for tenants
having a declawed cat. (For example, "Will consider declawed
cat only.") According to the author, this provision is modeled
on, but not identical to, language from the CA Fair Housing Act
that makes it unlawful for any person "to publish. . . an
advertisement, with respect to the sale or rental of a housing
accommodation that indicates any preference, limitation, or
discrimination based on race, color, religion, sex, etc? or an
intention to make that preference, limitation, or
discrimination." (Gov. Code Section 12955(c).)
2. "Refuse to allow the occupancy of any real property, refuse
to negotiate the occupancy of any real property, or to otherwise
make unavailable or deny to any other person the occupancy of
any real property because of that person's refusal to devocalize
or declaw any animal." According to the author, this provision
is modeled on Section 804(a) of the federal Fair Housing Act
which makes it unlawful in federal housing "to refuse to sell or
rent after the making of a bona fide offer, or to refuse to
negotiate for the sale or rental of, or otherwise make
unavailable or deny, a dwelling to any person because of race,
color, religion, sex, familial status, or national origin." (42
U.S.C. 3604.) This bill would prohibit those similar
discriminatory practices on the basis of whether a prospective
occupant would devocalize or declaw an animal. This type of
prohibition is intended to prohibit discrimination against a
person seeking housing, before any occupancy agreement or
tenancy is established in the real property, lest landlords or
property owners be able to evade the spirit of the law by simply
refusing to rent to persons on the same basis by which they
would be prohibited from discrimination if there was a lease.
3. "Discriminate in the terms of occupancy or the provision of
services against another person because that person owns an
animal that has not been devocalized or declawed." According to
the author, this provision is modeled on Section 804(b) of the
federal Fair Housing Act which makes it unlawful in federal
housing "to discriminate against any person in the terms,
conditions, or privileges of sale or rental of a dwelling, or in
the provision of services or facilities in connection therewith,
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because of race, color, religion, sex, familial status, or
national origin." (42 U.S.C. 3604.)
4. "Give preferential treatment in the terms of the right of
occupancy or the provision of services to another person because
that person owns an animal that has been devocalized or
declawed." While this provision complements the previous
prohibition of discrimination, there is no analogous provision
in either the federal or California Fair Housing Acts to giving
preferential treatment to someone who has declawed or
devocalized an animal. When considered together with the
previous anti-discrimination language on which it is based,
these two provisions operate to prohibit favorable treatment of
a person who has declawed or devocalized an animal, while
prohibiting discrimination against a person who has not declawed
or devocalized an animal-an equitable concept.
As proposed to be amended, this bill clarifies the civil penalty
structure for violations of this act, including who is
authorized to enforce these provisions and who may collect a
penalty. The author has proposed to amend the bill to
reorganize and recast the civil penalty provisions to clarify
who may enforce this act and who may collect the penalties in
those cases.
1. Standing to enforce the statute. First, the proposed
amendments provide that any person harmed by a violation has
standing to enforce the statute. According to the author, this
includes not only tenants and occupants, but also a third party
owner of an animal that was devocalized or declawed in violation
of this act-for example, in the aforementioned situation where a
tenant or occupant was temporarily taking care of the third
party's animal that was later devocalized or declawed.
In addition, an I.R.C Section 501(c)(3) organization dedicated
to the protection of animals is given standing to enforce this
act. According to the author, this will provide a mechanism for
potential enforcement in cases where a tenant or occupant cannot
or will not enforce the statute out of fear of retaliation by
the landlord.
2. Civil penalties of up to $2500 per animal for violations that
cause an animal to be declawed or devocalized. As proposed to
be amended, this bill clarifies that the maximum civil penalty
of up to $2500 per animal, assessed for each violation that
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causes the declawing or devocalizing of an animal, shall be paid
(unless the plaintiff is the 501(c)(3) organization) to the
person whose animal was declawed or devocalized-whether that
person is the tenant, occupant, or third party owner of the
animal. According to the author, this policy is intended to
compensate the owner of the animal for his damages (the declawed
animal) as well as the expense of the surgical procedure itself.
If, however, the plaintiff is the 501(c)(3) organization, then
the penalty amount will be paid to the organizational plaintiff
to provide an incentive to enforce the statute.
3. Civil penalties of up to $1000 for other violations. As
proposed to be amended, this bill provides that violation of
this section that has not caused the declawing or devocalizing
of an animal shall result in a civil penalty of not more than
one thousand dollars ($1,000) to be paid to the plaintiff.
According to the author, this amendment is intended to cap the
total civil penalty for "lesser" violations at $1000 total-the
penalty is not assessed for each violation in the case, just for
the first violation as long as it did not cause the declawing or
devocalization of any animal. This is sensible policy because
it prevents a plaintiff from alleging multiple $1000 violations
for each cat that was not declawed-which is a counting task more
open to argument than simple enumeration of cats that have been
declawed. In addition, the author's amendment corrects an
oversight to the penalty structure by clarifying that the $1000
penalty is to be paid to the plaintiff in all cases, whether the
plaintiff is an individual or an organization authorized to
enforce the statute.
As proposed to be amended, the bill makes new findings related
to the policy of the bill. The author has proposed to amend the
findings and declarations of the bill to focus attention on the
landlord-tenant relationship affected by the core policy of the
bill-the matter of principal importance to the Judiciary
Committee's analysis. Although the amended findings are very
brief and modest, they do establish the stark contrast between
the permanence of declawing and debarking procedures and the
temporary nature of most residential tenancy and occupancy
(which generally lasts only for a fixed term and may be
terminated upon notice by one of the parties.)
The California Veterinary Medical Association (CVMA) had
previously indicated it would support the bill if certain intent
language it found controversial was stricken from the bill. It
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is unknown whether the author's proposed amendments to the
findings section has caused CVMA to adopt a support position.
Pending Related Legislation : Existing law authorizes
corporations for the prevention of cruelty to animals to be
formed under the Nonprofit Public Benefit Corporation Law
(commencing with Section 10400 of the Corporations Code), and
allows the corporation to apply for appointment of humane
officers by a judge of the superior court after a specified
appointment and evaluation process. (Corp. Code 14502.) SB
1417 (Cox) of 2010 would implement new procedures and
requirements for the appointment, and subsequent training, of
humane officers by non-profit organizations formed for the
purpose of preventing cruelty to animals. SB 1417 was recently
passed by the Senate Judiciary Committee by a 4-0 vote and is
currently resides in Senate Appropriations.
Because this bill authorizes an I.R.C Section 501(c)(3)
organization dedicated to the protection of animals to enforce
violations of this act, it may go beyond existing law that
restricts authority to enforce animal laws to those
organizations that have appointed humane officers pursuant to
Corps. Code Section 14502. Consequently, the author may wish
to reconcile these provisions with Section 14502, especially if
significantly amended as proposed by SB 1417.
Prior Related Legislation. AB 1857 (Koretz), Ch. 876 of Stats.
2004, created a misdemeanor offense for any person to perform,
procure, or arrange for surgical claw removal, declawing,
onychectomy, or tendonectomy on an exotic or native wild cat
species, as defined, or from altering such a cat's toes, claws,
or paws in order to prevent their normal functioning.
ARGUMENTS IN SUPPORT : The United Animal Nations (UAN), an
animal advocacy organization that states it has over 9000
members in California, expresses its strong support of this bill
because it will protect landlords, tenants, and animals.
According to the UAN:
Some landlords have required declawing of cats in an
uninformed attempt to protect furnishings from being
scratched . . . The unintended consequence of
declawing can be that declawed cats are less likely to
use the litter box, probably because scratching in the
rough litter hurts their paws. These cats may instead
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urinate and defecate on floors, furniture, and in
other areas of the house. Besides creating a health
and public safety problem, the landlords may
inadvertently be causing more damage to their
property.
Debarking a dog requires that a veterinarian
surgically sever the animal's vocal cords. The animal
can have difficulty breathing for the rest of its life
because of scar tissue formation. Locating a silenced
dog in an emergency can also be difficult. Debarking
was made illegal in New Jersey because law enforcement
officers reported that the surgical technique was used
for criminal purposes to silence attack dogs so they
would not bark and warn their intended victims.
Federal law already prohibits Public Housing
Authorities from requiring tenants to devocalize their
animals.
The California Apartment Association (CAA), the largest
statewide rental housing trade association in the country, also
supports this bill because it enacts what is already the
Association's current practice. CAA explains:
CAA's leadership concluded years ago that it would not
include in its industry form and leases any
requirements that would require cats to be declawed or
dogs debarked. Instead the Association recommends
that property owners rely upon pet deposits to cover
any damage to the unit. CAA has taken a Support
position on AB 2743.
The Western Center on Law and Poverty (WCLP) and the California
Rural Legal Assistance Foundation also write in support of the
bill, stating:
On behalf of our low-income clients, we are pleased to
support AB 2743, which would prohibit landlords from
requiring that tenants' pets be declawed or debarked.
We are concerned that such requirements, though not
common now, may increase in the future. Low-income
families lack the funds to pay for these operations,
which can run into the hundreds of dollars.
We are also concerned that a debarking policy must
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infringe upon the meaningful exercise of the rights of
disabled tenants to keep a service animal, as required
by fair housing laws. A dog, able to bark, likely
would be a reasonable accommodation under current
laws, but disabled tenants would have to assert these
rights against a landlord who may be ignorant of the
law. For many, it isn't worth the time and effort.
ARGUMENTS IN OPPOSITION : The Animal Council, which identifies
itself as a nonprofit, public benefit corporation in California,
opposes this bill for a variety of reasons. The Council's
President relates that in over 25 years of experience counseling
landlords and tenants on residential pet tenancies, she has
never encountered a situation where either declawing or
debarking were a condition of tenancy. The Council also states:
We oppose using Civil Code provisions for residential
rentals to de-legitimize elective veterinary
procedures (i.e. declawing or debarking) that are
otherwise lawful veterinary practice in California as
determined through the veterinarian-client
relationship. . . . Debarking is not the same as
silence and would usually be ineffective (to resolve a
nuisance problem). Landlords simply reject a pet
completely, evict tenants whose pets cause problems
and hold tenants liable for physical damage caused by
the pet. For practical purposes, no landlord would be
willing to accept a tenant's offer to address an
actual problem pet in these ways for fear of late
retaliation. AB 2473 would reduce housing available
to pet owners and increase risks of shelter surrender
for problem pets.
REGISTERED SUPPORT / OPPOSITION :
Support
The Paw Project (sponsor)
Animal Advocates
California Apartment Association
Companion Animal Protection Society (CAPS)
Nolan-Taft Management
Paw PAC
United Animal Nations (UAN)
Western Center on Law and Poverty
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Opposition
The Animal Council
Analysis Prepared by : Anthony Lew / JUD. / (916) 319-2334