BILL ANALYSIS                                                                                                                                                                                                    






                             SENATE JUDICIARY COMMITTEE
                           Senator Ellen M. Corbett, Chair
                              2009-2010 Regular Session


          AB 655
          Assemblymember Emmerson
          As Amended May 19, 2009
          Hearing Date: July 14, 2009
          Business and Professions Code
          BCP:jd
                    

                                        SUBJECT
                                          
                           Self-Service Storage Facilities

                                      DESCRIPTION  

          This bill would remove the ability for an occupant of a  
          self-service storage facility to object to a lien sale by  
          executing a declaration of objection, and, instead, require the  
          occupant to file an action in court.

          This bill would additionally:
           standardize the time frame in which the owner may deny an  
            occupant access to a space, enter the space, and remove the  
            property for safe keeping; 
           enhance the notice of lien sale; 
           permit a person claiming a right to stored goods to pay the  
            lien amount and one month's rent in advance, but if a court  
            order is not obtained within 30 days, the claimant must pay  
            the owner a monthly rental charge, and if that is not paid,  
            the owner may sell or dispose of the property without  
            liability; and
           other clarifying changes.

                                      BACKGROUND  

          Existing law, the California Self-Service Storage Facility Act,  
          governs self-service storage facilities and specifies certain  
          procedures to be followed when their occupants are delinquent in  
          their payments.  When an occupant is delinquent, the owner must  
          first send a preliminary lien notice that informs them that if  
          they do not pay the amount due that their right to use the space  
          will terminate, they will be denied access, and an owner's lien  
                                                                (more)



          AB 655 (Emerson)
          Page 2 of ?



          will be imposed on all stored property.  If the occupant fails  
          to pay the amount, the owner may then send a notice of lien  
          sale, which states that the property will be sold to satisfy the  
          lien on or after a specified date (not less than 14 days after  
          mailing) unless: (1) the amount of the lien is paid; or (2) the  
          occupant executes and returns a declaration in opposition to the  
          lien sale.  If that declaration is returned, the owner must file  
          a court action to enforce the lien.

          This bill would modify existing law by, among other things,  
          removing the ability to return the above declaration of  
          objection, enhancing the notice of lien sale, and standardizing  
          the time frame between the sending of the preliminary lien  
          notice and the ability to deny an occupant access, as specified.

                                CHANGES TO EXISTING LAW
           
           Existing law  , the California Self-Service Storage Facility Act,  
          specifies remedies and procedures for self-service storage  
          facility owners when occupants are delinquent in paying rent or  
          other charges.  (Bus. & Prof. Code Sec. 21700 et seq.)

           Existing law  provides that if an owner sends an occupant a  
          preliminary lien notice by certified mail, the owner may, upon  
          the effective date of the lien, deny the occupant access to the  
          space, enter the space, and remove property to safe keeping.   
          However, if the owner sends the preliminary lien notice by  
          first-class mail with certificate of mailing, the owner may not  
          remove the property for at least 14 days following the effective  
          date of the lien.  (Bus. & Prof. Code Sec. 21705.)

           Existing law  requires owners to send occupants a notice of lien  
          sale that states the property will be sold to satisfy the lien  
          after a specified date that is not less than 14 days from the  
          date of mailing unless: (1) the amount of the lien is paid; or  
          (2) the occupant returns a declaration in opposition to lien  
          sale in a specified form under penalty of perjury.  (Bus. &  
          Prof. Code 21705 (c).)

           Existing law  permits a person claiming a right to the stored  
          goods, prior to any lien sale, to pay the lien amount and  
          reasonable expenses.  In that event, the goods shall not be  
          sold, but shall be retained by the owner subject to the court's  
          disposition of the property.  (Bus. & Prof. Code Sec. 21709.)  

           This bill  would repeal provisions that currently allow an  
                                                                      



          AB 655 (Emerson)
          Page 3 of ?



          occupant to stop a lien sale by returning a declaration in  
          opposition to that sale, and, instead require an occupant to  
          challenge the sale by filing a court action.  

           This bill  would provide that if a preliminary lien notice has  
          been sent and the total sum due has not been paid within 14 days  
          of the specified termination date, the owner may deny the  
          occupant access to the space, enter the space, and remove the  
          property for safe keeping.

           This bill  would require an owner, after sending a preliminary  
          lien notice, to send the occupant a notice of lien sale that  
          states all of the following:
           the occupant's right to use the storage space has terminated  
            and that the occupant no longer has access to the property;
           the stored property is subject to a lien, the current amount  
            of the lien, and that the lien will continue to increase if  
            rent is not paid;
           that the property will be sold to satisfy the lien after a  
            specified date that is not less than 21 days from the date of  
            mailing the notice;
           a statement that the occupant may regain full use of the space  
            by paying the full lien amount prior to the (above) specified  
            date;
           a conspicuous statement that the occupant may challenge the  
            sale by filing an action in any court having jurisdiction to  
            render a judgment in the amount of the lien; and
           that any excess proceeds of the sale (over the lien amount and  
            costs of sale) will be retained by the owner and  may be  
            reclaimed by the occupant or claimed by another person at any  
            time for a period of one year from the sale and that the  
            proceeds will then escheat to the county where the sale takes  
            place. 

           This bill  would provide that prior to any lien sale, any person  
          claiming a right to the goods may pay the amount necessary to  
          satisfy the lien together with one month's rent in advance.  In  
          that event the goods shall not be sold, but shall be retained by  
          the owner pending a court order directing the disposition of the  
          property.  

           This bill  would provide that if a court order is not obtained  
          within 30 days, as specified, the claimant shall pay the owner  
          the monthly rental charge for the space where the property is  
          stored.  If the claimant does not pay that rent, the owner may  
          dispose or sell the personal property in accordance with the  
                                                                      



          AB 655 (Emerson)
          Page 4 of ?



          above lien sale provisions.  Furthermore, this bill would  
          provide that the owner shall have no liability for the sale or  
          other disposition of the personal property to any claimant who  
          fails to secure a court order or pay that rental charge.   

                                        COMMENT
           
          1.  Stated need for the bill  

          According to the author: 

            AB 655 will make several changes to the California  
            Self-Service Storage Facility Act that will make it more  
            consistent with other statutory lien enforcement procedures  
            in California as well as other states.  This bill eliminates  
            the Declaration of Opposition to Lien Sale and replaces it  
            with a more clear Notice of Lien Sale to delinquent  
            occupants to inform them of their right to file suit to stop  
            the sale of their property.  AB 655 will also change the  
            required method of sending the Notice of Lien Sale from  
            certified mail to first-class mail with certificate of  
            mailing.

          2.   Impact of removing the declaration of opposition  

          The committee received numerous letters from various  
          self-storage facilities within California that all state: "I am  
          especially troubled by the current requirement under the law of  
          sending the Declaration in Opposition.  Only California and  
          Nevada have such a requirement and it places a significant  
          burden upon many of the small businesses within the Self storage  
          Industry in California."  The declaration at issue is one that  
          owners must send to the occupant along with the notice of lien  
          sale.  If the occupant completes the form and returns it to the  
          owner prior to date of sale, the owner must seek a court order  
          to enforce the lien.

          By replacing the declaration with an enhanced notice of lien  
          sale that includes a "conspicuous statement" that the occupant  
          may challenge the sale by filing an action in any court having  
          jurisdiction to render a judgment in amount of the lien  
          (arguably including small claims court), this bill would shift  
          the burden of filing an action from the owner to the occupant.   
          It should be noted that this represents a fundamental,  
          significant change in law - the current statutory provisions  
          have been in place (and apparently working) since 1981.  
                                                                      



          AB 655 (Emerson)
          Page 5 of ?




          While the current process does arguably impose a burden on  
          self-storage owners whose occupants object to the sale, the  
          shifting of the burden onto the occupant raises several issues  
          for individuals who are physically unable to file a timely  
          action.  For example, an occupant may reside out of state and be  
          unable to travel to California and file an action to challenge  
          the sale.  Similarly, an individual who is in the military and  
          stationed overseas would have the opportunity to object to the  
          sale under existing law, but would be otherwise unable to  
          physically travel to California and file an action to protect  
          their belongings.

          Absent complete information regarding the number of times an  
          objection is actually sent and the reasons for sending those  
          objections, the committee should consider whether it is  
          appropriate to remove this consumer protection that has been in  
          place for 28 years.  If, as the author states, "[m]ost  
          delinquent occupants are confused by the Declaration and its  
          intentions," the author should work with committee staff to  
          clarify the declaration so that the protection can be preserved  
          while clarifying existing law.  

          SHOULD THE AUTHOR WORK WITH COMMITTEE STAFF TO, INSTEAD, CLARIFY  
          THE DECLARATION TO ELIMINATE CONFUSION THAT MAY EXIST?

          The committee should consider whether this would be an  
          appropriate issue for the Law Revision Commission to study and  
          issue a report - such a report would provide guidance for how  
          best to clarify, or if supported by evidence, eliminate the  
          declaration of objection.

          ALTERNATIVELY, SHOULD THE LAW REVISION COMMISSION STUDY THE  
          DECLARATION OF OBJECTION?




          3.   Immunity provision  

          Under existing law, any person claiming a right to goods that  
          have been stored may pay the amount necessary to satisfy the  
          lien and the reasonable expenses incurred.  In that case, the  
          goods shall not be sold, and are retained by the owner pending a  
          court order directing disposition of the property.

                                                                      



          AB 655 (Emerson)
          Page 6 of ?



          This bill would modify that provision by, instead, requiring  
          that person to pay the amount necessary to satisfy the lien  
          together with one month's rent in advance.  If a court order is  
          not obtained within 30 days following the date of that payment,  
          the claimant must pay the owner the monthly rental charge for  
          the space, and if they do not make that payment, the owner may  
          sell or dispose of the property.  The bill would additionally  
          provide that the owner shall not be liable for the sale or other  
          disposition of the personal property to any claimant who fails  
          to secure a court order or pay the required rental charge.

          It is unclear how an owner would be liable if they are complying  
          with their proposed statutory duties thus, the following  
          amendment is suggested to clarify that the immunity applies only  
          when the owner has fully complied with the requirements of the  
          chapter.  That same immunity appears in Business and Professions  
          Code Section 21708 that governs the issue of the owner  
          delivering possession of any personal property to a person with  
          a perfected security interest that has paid the total amount  
          due, as specified.

           Suggested amendment:
           
          On page 5, line 37, after "section" insert:

            , provided the owner has fully complied with the requirements  
            of this chapter.

          4.   Additional provisions  

          Under existing law, an owner may send a preliminary lien notice  
          either by certified mail or by first-class mail with certificate  
          of mailing.  When the notice is sent by certified mail, the  
          owner may deny an occupant access to the space, enter the space,  
          and remove property, if the lien is not paid by the date  
          specified in the lien notice (the termination date).  An owner  
          must wait 14 days to take the above actions if the notice is  
          sent by first-class mail with a certificate of mailing.  This  
          bill would standardize that time frame by providing that an  
          owner who has sent a preliminary lien notice (by either type of  
          mailing) may enter the space, deny the occupant access, and  
          remove property if the occupant has not paid the lien amount  
          within 14 days of the termination date specified in the notice.

          This bill would also extend the sale date from not less than 14  
          days after the notice of lien sale, to not less than 21 days,  
                                                                      



          AB 655 (Emerson)
          Page 7 of ?



          and make other technical, clarifying changes.
           Support  :  over 120 individuals

           Opposition  : None Known

                                       HISTORY
           
           Source  : California Self Storage Association

           Related Pending Legislation  :  None Known

           Prior Legislation : AB 790 (Frommer, Chapter 267, Statutes of  
          2003), authorized an owner to provide preliminary lien notice by  
          regular first-class mail (in addition to certified mail) if he  
          or she obtains a certificate of mailing indicating the date of  
          mailing, but prohibited the owner from removing property until  
          14 days after the lien date if using this method rather than  
          certified mail.

           Prior Vote  :

          Assembly Business and Professions Committee (Ayes 8, Noes 0)
          Assembly Judiciary Committee (Ayes 10, Noes 0)
          Assembly Floor (Ayes 76, Noes 0)

                                   **************