BILL ANALYSIS                                                                                                                                                                                                    






          
                SENATE HOUSING & COMMUNITY DEVELOPMENT COMMITTEE
                      Senator Denise Moreno Ducheny, Chair


          Bill No:                             AB 1836Hearing:June 7,  
          2004
          Author:                              HarmanFiscal:No
          Version:                             June 1,  
          2004Consultant:Michelle Rubalcava

              COMMON INTEREST DEVELOPMENTS AND DISPUTE RESOLUTION

           Background and Existing Law  :

          A common-interest development (CID) is a form of real  
          estate where each homeowner has an exclusive interest in a  
          unit or lot and a shared or undivided interest in common  
          area property.  Condominiums, planned unit developments,  
          stock cooperatives, and community apartments all fall under  
          the umbrella of common interest developments.  The  
          Davis-Stirling Common Interest Development Act provides the  
          legal framework under which homeowner associations operate  
          in common interest developments.  In addition to the  
          requirements of the Act, each CID is governed by a  
          homeowner association according to the recorded  
          declarations, bylaws, and operating rules of the  
          association.


          The Davis-Stirling Act provision relating to alternative  
          dispute resolutions (ADR) states that declarations of the  
          association shall bind all owners of separate interests in  
          the development.  Prior to the filing of a civil action by  
          either an association or a homeowner solely for declaratory  
          relief or injunctive relief, or for declaratory relief or  
          injunctive relief in conjunction with a claim for monetary  
          damages, other than association assessments, not in excess  
          of five thousand dollars ($5,000), related to the  
          enforcement of the governing documents, the parties shall  
          endeavor to submit their dispute to a form of alternative  
          dispute resolution such as mediation or arbitration.  The  
          form of alternative dispute resolution chosen may be  
          binding or non-binding at the option of the parties.  Any  
          party to such a dispute may initiate this process by  
          serving on another party to the dispute a Request for  




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          Resolution.


          The Request for Resolution shall include (1) a brief  
          description of the dispute between the parties, (2) a  
          request for alternative dispute resolution, and (3) a  
          notice that the party receiving the Request for Resolution  
          is required to respond within 30 days of receipt or it will  
          be deemed rejected.  Service of the Request for Resolution  
          shall be in the same manner as prescribed for service in a  
          small claims action as provided in Section 116.340 of the  
          Code of Civil Procedure.  Parties receiving a Request for  
          Resolution shall have 30 days following service of the  
          Request for Resolution to accept or reject alternative  
          dispute resolution and, if not accepted within the 30-day  
          period by a party, shall be deemed rejected by that party.   
          If alternative dispute resolution is accepted by the party  
          upon whom the Request for Resolution is served, the  
          alternative dispute resolution shall be completed within 90  
          days of receipt of the acceptance by the party initiating  
          the Request for Resolution, unless extended by written  
          stipulation signed by both parties.  The costs of the  
          alternative dispute resolution shall be borne by the  
          parties.

          The Davis-Stirling Act also includes provisions regarding  
          association management.  These provisions state that  
          meetings of the membership of the association shall be  
          conducted in accordance with a recognized system of  
          parliamentary procedure, to provide notice to members  
          before an action is presented, require all meetings to be  
          open to the membership unless the board meets in an  
          executive session, requires minutes or a summary of the  
          minutes of a board meeting to be distributed within 30 days  
          of the meeting, and that a homeowner may dispute  
          assessments so long as the homeowner pays the amount owed  
          and any fees under protest while the dispute is resolved  
          either through an alternative dispute resolution or the  
          courts.

           Proposed Law  :

          Assembly Bill 1836 enacts recommendations made by the  
          California Law Revision Commission regarding the  
          requirements and process for alternative dispute resolution  
          used by homeowner associations and homeowners.




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          Specifically, this bill:
           States that  a governing document other than the  
            declaration may be enforced by the association against a  
            homeowner or by a homeowner against the association.

           States that in an action to enforce the governing  
            documents, the prevailing party shall be awarded  
            reasonable attorney's fees and costs.

           Requires that an association along with the homeowners  
            develop a fair and reasonable internal process for  
            handling disputes between the association and a  
            homeowner.  This internal process would not require a  
            neutral third party and also exempts assessment disputes  
            from the internal dispute process.

           Outlines the requirements for a fair and reasonable  
            internal dispute process.  Including but not limited to:
          a)  Granting the right to either the association or the  
            homeowner to invoke the dispute procedure.  Such a  
            request must be made in writing.  In addition, if the  
            procedure is invoked by a homeowner the association must  
            participate, but if the procedure is invoked by the  
            association a homeowner may choose not to participate in  
            the procedure.
          b)  Stating the maximum time for the association to act on  
            a request for invoking the procedure.  The deadline  
            should be a prompt deadline.
          c)  No fees shall be charged to a homeowner if they wish to  
            participate in the procedure.

           Encourages an association to make reasonable use of local  
            low-cost mediation programs such as those listed on the  
            websites of the Department of Consumer Affairs and the  
            United States Department of Housing and Urban  
            Development.

           Requires that a party attempt to submit their dispute to  
            alternative dispute resolution prior to filing suit if  
            they are seeking declaratory, injunctive or writ relief  
            or for that relief in conjunction with a claim of damages  
            less than $5,000. 

           Defines alternative dispute resolution as mediation,  
            arbitration, conciliation or other nonjudicial procedure  




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            involving a neutral third party.  The form may be binding  
            or nonbinding at the choice of the parties involved.

           Requires alternative dispute resolution prior to filing  
            suit for any action to enforce the Davis Stirling Act,  
            Nonprofit Mutual Benefit Corporation Law, or the  
            governing documents of the association.

           Requires that in order to initiate the process of  
            alternative dispute resolution any party may serve all  
            other parties with a Request for Resolution that  
            includes:
          a) A brief description of the dispute and a request for  
            alternative dispute resolution;
          b) A notice that the receiving party is required to respond  
            within 30 days or the request will be deemed denied; and,
          c) A copy of the articles enacted by this bill establishing  
            the process for alternative dispute resolution.

           Requires a Request for Resolution to be by personal  
            delivery, first class mail, express mail, fax, or other  
            means that would reasonably be assumed to notify the  
            receiving party.

           Provides that a court may take into account a party's  
            prior refusal for requested alternative dispute  
            resolution when determining the amount of an award in a  
            subsequent suit.

           Comments  :

          1.   Purpose of the bill.   The author states that this bill  
          was introduced to enact recommendations made by the  
          California Law Revision Commission (CLRC) which revise the  
          requirements and process for alternative dispute resolution  
          used by homeowner associations and homeowners.

          A common interest housing development is characterized by  
          (1) separate ownership of dwelling space coupled with an  
          undivided interest in the common area, (2) covenants,  
          conditions, and restrictions that limit use of  both the  
          common area and separate ownership interests, and (3)  
          administration of common property by a homeowners  
          association.  This structure inevitably leads to conflicts  
          within the development, either between the association  
          management and a homeowner, or between homeowners.  These  




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          disputes typically fall into one of several categories,  
          such as, financial disputes, architectural controls, pet  
          issues, use of private space and personal interaction.

          As part of its general study of common interest development  
          law, the CLRC found that participants in alternative  
          dispute resolution in CIDs reported mixed results.  The  
          CLRC determined that this was as a result of current  
          structural factors that work against effective alternative  
          dispute resolution.  For example, the relative inequality  
          of bargaining position between the association and an  
          individual homeowner, as well as, the cost of invoking a  
          neutral resolution process.  It is the opinion of the CLRC  
          that the existing alternative dispute resolution mechanisms  
          to cope with these conflicts inherent within a CID is  
          limited.  Therefore, the CLRC drafted a report wherein they  
          propose improving the current dispute resolution process  
          for common interest developments.

          2.   Two tier process created by AB 1836.   Assembly Bill  
          1836 creates a two tier dispute resolution process that  
          must be followed before a party may bring an action to the  
          courts.  The first tier is an informal internal process  
          which must be developed by the homeowner association and  
          the homeowners.  This internal dispute process would seek  
          to encourage communication between the association and the  
          homeowner.  This step in dispute resolution seems too basic  
          to have to codify but the CLRC, sponsors of the bill, feel  
          that most associations need these basic ground rules.  This  
          first tier would not bind the parties to any decision  
          unless both parties agreed and in addition this first step  
          is designed to be a no cost process, since this first step  
          does not require the mediation by a neutral third party.

          The second tier is the CLRC's recommendations to reform and  
          strengthen the existing alternative dispute resolution.  In  
          particular, alternative dispute resolution is expanded to  
          those actions that arise out of an association's own  
          documents and bylaws or relevant statutes, such as the  
          Davis-Stirling Act and the Nonprofit Mutual Benefit  
          Corporation Law.  Assembly Bill 1836 also requires the use  
          of local dispute resolution programs to the extent that it  
          is deemed reasonable.  For example, some counties do not  
          have local dispute resolution programs and therefore it  
          would not be reasonable to mandate the use of a nonexistent  
          program.




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          3.   Concerns with the bill.   The Congress of California  
          Seniors (CCS) along with the California Alliance for  
          Retired Americans have voiced some concerns with the  
          current version of Assembly Bill 1836.  In particular, CCS  
          is troubled that the alternative dispute resolution  
          provisions outlined in the bill do not apply to assessment  
          disputes.  CCS argues, "Assessment disputes are the precise  
          kind of disputes which are in desperate need of resolution.  
           We have collected countless examples of such disputes in  
          which the homeowner paid the full amount under protest,  
          requested alternative dispute resolution, and only after  
          making full payment was told by the other disputant - the  
          association - that no ADR mechanisms exist for resolving  
          the counter-claims.  More often, the association (or the  
          debt collector acting as the association's agent) simply  
          ignores the homeowner's request for alternative dispute  
          resolution."

          The sponsors of the bill, CLRC, respond that assessment  
          disputes were purposely carved out of AB 1836 because there  
          already exists a process specifically designed for  
          assessment disputes.  That process was created in AB 2289  
          (Kehoe, 2002), which CCS sponsored.  CLRC argues that the  
          process established by AB 2289 is a very detailed process  
          of how a homeowner can resolve assessment disputes and they  
          were reluctant to confuse parties as to which process  
          should be adhered to when dealing with assessment disputes.

          CCS argues that AB 2289 has not produced the desired  
          results.  They argue that AB 2289 (Kehoe, 2002) allows a  
          homeowner to meet with the board regarding an assessment  
          dispute privately.  The process allows for the debt to be  
          verified and then the possibility of creating a payment  
          plan.  The problem that is resulting is that AB 2289 did  
          not require that an association agree to a payment plan.   
          The resulting practice has been that if an association is  
          not pleased with the proposed payment plan, they can  
          legally reject it and then threaten foreclosure as a way to  
          make the homeowner agree to a more palatable payment plan  
          for the association.

          CCS feels that currently there is no way to actually  
          resolve disputes because the association still has the  
          upper hand in negotiations.  They argue that if assessment  
          disputes are added to AB 1836 this will allow the dispute  




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          to go to a neutral third party instead of becoming a tug of  
          war between the association and the homeowner.

          The committee may wish to consider striking the provision  
          of the bill which specifically carves out assessment  
          disputes from the bill.

          4.   Double Referral.   The Senate Rules Committee has double  
          referred this measure to the Senate Committee on Housing  
          and Community Development as well as the Senate Judiciary  
          Committee.  If this measure passes out of the current  
          committee it must be referred to the Senate Judiciary  
          Committee.

           Related Legislation  :

           AB 2376 (Bates) inter alia requires a homeowner  
            association to provide a fair and reasonable process for  
            reviewing a request by a homeowner for a physical  
            alteration to their unit or the common area.  This bill  
            is also sponsored by the California Law Review  
            Commission.  AB 2376 will be heard in this committee on  
            June 21.

           AB 2598 (Steinberg) inter alia prohibits the use of the  
            non-judicial foreclosure process by homeowner  
            associations in collecting overdue assessments when the  
            underlying debt is for the failure to pay association  
            assessments or dues.  AB 2598 is in the Senate pending  
            referral.

           SB 1682 (Ducheny) inter alia requires homeowner  
            associations to offer binding arbitration before placing  
            a lien on the property or before initiating foreclosure  
            proceedings.  SB 1682 is in the Assembly Judiciary  
            Committee.

           Previous Actions  :

          Assembly Floor:                         76-0
          Assembly Judiciary:                     11-0
          Assembly Housing and Community Development:  9-0

           Support and Opposition  :  (6/2/04)

           Support  : California Law Revision Commission (Sponsor)




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                   American Homeowners Resource Center

           Opposition  :  none received