BILL ANALYSIS                                                                                                                                                                                                    �






                             SENATE JUDICIARY COMMITTEE
                         Senator Hannah-Beth Jackson, Chair
                              2013-2014 Regular Session

          SB 1439 (Leno)
          As Amended April 1, 2014
          Hearing Date: May 6, 2014
          Fiscal: No
          Urgency: No
          NR


                                        SUBJECT
                                           
               Residential Real Property: Withdrawal of Accommodations

                                      DESCRIPTION
           
          This bill would allow the City and County of San Francisco to  
          limit the ability of a rental property owner to exercise its  
          "Ellis Act" rights (which allow a property owner to get out of  
          the rental business and in the process evict all tenants from  
          the rental property, notwithstanding any local rent control  
          laws) to cases where the owner has owned the property for at  
          least five years.  

          This bill would additionally allow the City and County of San  
          Francisco to:
           prohibit any owner of a building for which an Ellis Act notice  
            has been submitted from withdrawing any other property that he  
            or she acquired after submitting the notice for the former  
            property;
           prohibit an owner from acting in concert directly or  
            indirectly with a co-owner, successive owner, prospective  
            owner, or other person to circumvent the above prohibitions; 
           require an owner submitting an Ellis Act notice to identify  
            each person or entity with an ownership interest in the  
            building, including persons with an ownership interest in a  
            corporate entity; and
           provide that a violator of any of these provisions is liable  
            to the tenant for actual damages, special damages of at least  
            $2,000 for each violation, and reasonable attorney fees and  
            court costs as determined by the court.   

                                      BACKGROUND  

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          The Ellis Act was adopted in 1985 by SB 505 (Ellis, Chapter  
          1509, Statutes of 1985) following the California Supreme Court's  
          decision in Nash v. City of Santa Monica  (1984) 37 Cal.3d 97,  
          which upheld the power of a city, in the context of a land use  
          ordinance, to require a residential property owner to obtain a  
          removal permit under specified criteria before the owner could  
          demolish the rental property and remove it from the rental  
          marketplace.  SB 505 preempted the ability of local governments  
          to adopt a local ordinance that prohibited rental property  
          owners from removing a rental property from the marketplace, and  
          specified certain procedures should a property owner decide to  
          exercise its "Ellis" rights.  

          Reports indicate that evictions in San Francisco are at their  
          highest level in over a decade, and "that use of the Ellis  
          Act-which allows a property owner to oust tenants in order to  
          get out of the rental business-nearly doubled for the third  
          straight year.  City officials and tenant advocates say most  
          uses of the Ellis Act are by real estate speculators who have  
          just purchased a rent-controlled building.  But while Ellis Act  
          evictions in the past year rose from 116 to 216, they only  
          represented about 11 percent of all evictions.  Still, such  
          evictions remove rental units from the City's stock and make the  
          property much more valuable." (Chris Roberts, SF evictions keep  
          rising, latest report shows, SF Examiner, March 13, 2014.)

          This bill seeks to ensure that real estate speculators in San  
          Francisco do not buy rent-controlled property and empty it of  
          long-term tenants. Accordingly, this bill would authorize San  
          Francisco to prohibit owners of less than five years from  
          invoking the Ellis Act, require disclosure of all owners in a  
          building which has invoked the Ellis Act, and provide a cause of  
          action with statutory penalties against owners who violate the  
          provisions of this bill. 

                                CHANGES TO EXISTING LAW
           
           Existing law  generally prohibits public entities from adopting  
          any statute, ordinance, or regulation, or taking any  
          administrative action, to compel an owner of residential real  
          property to offer or to continue to offer residential property  
          for rent or lease. (Gov. Code Section 7060 et. seq.)

           Existing law  provides that a public entity with rental control  
          laws may require the owner to notify the entity of an intent to  
          withdraw residential property from rent or lease, and may  
                                                                      



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          establish the date on which the property is withdrawn from rent  
          or lease at 120 days from the delivery of that notice to the  
          public entity.  However, if a tenant or lessee is at least 62  
          years of age or is disabled, and has lived in the rental  
          property for at least one year prior to the delivery date of the  
          notice of intent to withdraw, existing law extends the date of  
          withdrawal and the tenancy of that qualified tenant to one year  
          after the delivery of the notice, as specified. (Gov. Code Sec.  
          7060.4.)

           Existing law  authorizes a public entity having a system of rent  
          controls to require the following when the owner of a rental  
          property subject to rent controls has exercised his or her Ellis  
          rights:
           If the property is returned to the rental market within five  
            years following the filing of the notice of intent to withdraw  
            or within five years after the property's withdrawal, the  
            rental unit must be offered at the rent level, as specified,  
            in effect when the withdrawal notice was filed; and further,  
            if that returned rental unit is offered again for rent at any  
            time during the five-year period, the rental rate for any  
            re-rental of the returned unit shall be that rent level.
           If the property is offered for rent within two years the  
            property was withdrawn from the market: 
             o    the property owner is liable to any evicted tenant for  
               actual and exemplary damages; 
             o     the public entity may also sue the property owner for  
               exemplary damages for the displacement of tenants and  
               lessees; and
             o    the property owner must offer former evicted tenants the  
               right of first refusal to reoccupy the property pursuant to  
               a reinstituted rental agreement where the tenant has  
               advised the owner of this entitlement within 30 days of the  
               tenant's eviction from the premises when the property was  
               first withdrawn.    
           If the property is returned to the rental market within 10  
            years from the date of withdrawal, the owner must first offer  
            the returned unit to the tenant displaced by the withdrawal  
            where the tenant has requested the offer within 30 days after  
            the owner had notified the public entity of an intention to  
            offer the property again for rent.  (Gov. Code Sec. 7060.2.)

           This bill  would authorize the City and County of San Francisco  
          to adopt an ordinance, resolution, or regulation to prohibit an  
          owner from submitting a notice to withdraw a building pursuant  
          to the Ellis Act unless all the owners of the property have been  
                                                                      



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          owners for at least five continuous years.  If the owner is a  
          corporate entity, all persons or entities with an ownership  
          interest must have held that interest for five continuous years.

           This bill  would authorize the City and County of San Francisco  
          to adopt an ordinance, resolution, or regulation to require an  
          owner submitting an Ellis Act notice to identify each person or  
          entity with an ownership interest in the building, including  
          persons with an ownership interest in a corporate entity, and  
          this information shall be available for public inspection.

           This bill  would additionally authorize the City and County of  
          San Francisco to adopt ordinances, resolutions, or regulations  
          to:
           prohibit any owner of a building for which an Ellis Act notice  
            has been submitted from withdrawing any other property that he  
            or she acquired after submitting the notice for the initial  
            property;
           prohibit an owner from acting in concert directly or  
            indirectly with a co-owner, successive owner, prospective  
            owner, or other person to circumvent the above two  
            prohibitions; and
           provide that a violator of any of these provisions is liable  
            to the tenant for actual damages, special damages of at least  
            $2,000 for each violation, and reasonable attorney fees and  
            court costs determined by the court. 
              
           This bill  would make uncodified declarations and findings  
          related to the increase in Ellis Act evictions in San Francisco.
                                        COMMENT
           
           1.Stated need for the bill

           According to the author: 
           
             Ellis Act evictions have tripled in San Francisco in the last  
            year.  More than 300 units were taken off the rental market.   
            But that figure understates the impact of the Act.  Many  
            evictions occur off the books. Ellis Act threats lead many  
            tenants to vacate without paperwork actually being filed.   
            Neighboring tenants live in fear that the evictions occurring  
            around them will soon happen to them.  Fifty percent of the  
            evictions in 2013 were done by owners who had owned the  
            property for less than one year before invoking the Act, the  
            majority occurring during the first six months of ownership.   
            These are not the landlords the Act was designed to help.
                                                                      



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            The spirit of the Act was to allow property owners a way out  
            of the rental business, not to give windfall profits to  
            speculators willing to exploit the Act by entering the rental  
            business just to exit it.  This misuse of the Act does damage  
            to renters and their communities.  Cities are already  
            empowered by the Act to adopt specified rules to mitigate the  
            impact of eviction and prevent re-rental in violation of the  
            Act.  This bill will allow San Francisco to respond to the  
            conditions it is currently experiencing by authorizing the  
            city to enact additional measures to stop misuses of the Act  
            by speculators.

           2.Applies only to the city and county of San Francisco

           This bill would apply only "to a city that is also a county," or  
          San Francisco, and would allow San Francisco to  adopt a local  
          ordinance or regulation prohibiting owners of rental property of  
          less than five years from invoking their Ellis Act rights with  
          regards to that property.  This bill would also allow San  
          Francisco to adopt other measures to address the current housing  
          crisis including 1) restricting what options are available on  
          rental properties purchased after a notice of intent to withdraw  
          accommodations has been filed, 2) requiring disclosure of all  
          owners in any property that is "Ellised," and 3) damages for  
          violations of the provisions of this bill. 

           In October of 2012, the Huffington Post reported that San  
          Francisco was the most unaffordable city in the country for home  
          ownership, a problem which stretches to the rental market as  
          well.  The article pointed to a number of contributing factors,  
          including the fact that it is a densely developed coastal area  
          with little room for new construction and geographic boundaries  
          preventing outward expansion.  However, the problem is further  
          exacerbated "by the social-media fueled tech boom that has  
          brought lots of high-earners into the region?However, the city's  
          ability to construct new housing hasn't been able to keep pace.   
          In 2011, San Francisco only added 418 units for new housing over  
          the course of an entire year." (Aaron Sankin,  Most Expensive  
          City in America: San Francisco Most Unaffordable City for Home  
          Ownership, October 22, 2014, found at  
          http://www.huffingtonpost.com/2012/10/22/most-expensive-city_n_  
          2002532.html as of May 1, 2013.)  Mayor Edwin M. Lee, a  
          co-sponsor of this bill, writes: 

            The State Legislature passed the Ellis Act in 1985, allowing  
                                                                      



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            property owners to leave the rental housing business by  
            evicting their tenants.  In San Francisco, the straightforward  
            law is being misused.  Since emerging from the Great  
            Recession, the City has experienced a dramatic surge in Ellis  
            Act evictions.  In the last year, Ellis Act evictions have  
            increased 86 percent, on top of an 81 percent increase in  
            2012.  These evictions are not being carried out by long-term  
            property owners, leaving the rental business to retire from  
            being landlords.  Instead, a small group of bad actors have  
            become serial evictors, buying tenanted, rent-controlled  
            buildings with6 the intention of invoking the Ellis Act and  
            reselling a vacant building at a higher price. 

           3.Limitation on subsequently purchased properties
                
          The basic intent of the Ellis Act was to permit landlords to go  
          out of business. (See Gov. Code Sec. 7060.7.) This bill would  
          prohibit an owner who invokes his Ellis rights with regards to a  
          property, from "Ellising" a property purchased after the notice  
          of intent to withdraw accommodations on the former property was  
          filed.  According to the author, this provision is intended to  
          prevent serial evictors from purchasing additional properties  
          which they intend to take off the rental market after noticing  
          their intent to exit the real estate business.  

          The California Association of Realtors writes in opposition that  
          this bill "prohibits an owner from applying the Ellis Act to  
          more than one rental property.  This would require an owner to  
          remain in a money-losing investment for perpetuity and serves to  
          discourage new investment in such housing." 

          Staff notes that this prohibition applies only to properties  
          purchased after an owner has used the Ellis Act on a previously  
          owned property, and thus does not limit application of the Ellis  
          Act to only one rental property.  Landlords who own multiple  
          properties may invoke the Ellis Act on as many as they find  
          necessary, as long as the property was not purchased after the  
          notice of intent to withdraw was filed.  However, this  
          restriction could apply to more than just speculators by also  
          restricting those owners who purchase a property a significant  
          amount of time later which they wish to eventually remove from  
          the rental market as well.  To ensure that this bill does target  
          speculators,  the author should consider limiting the perpetual  
          effect of this provision while still ensuring that the ability  
          of speculators to purchase properties with the intention of  
          evicting tenants is curbed.  The following amendment would place  
                                                                      



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          the prohibition only on rental properties purchased within ten  
          years of an owner's intent to withdraw accommodations on the  
          previously owned property.   

             Author's amendment
             
            On page 2, line 21 after "accommodations" insert "within ten  
            years of that filing"
           4.Opposition's remaining concerns
           
          The Civil Justice Association of California (CJAC) argues that  
          this bill would create problems for landlords, their families,  
          and those who they contract with, and would encourage more  
          lawsuits against property owners.  CJAC writes "Over the years  
          rental property owners have relied on the Ellis Act in order to  
          avoid the potential for bankruptcy or to move into their own  
          rental units.  In order to address a housing shortage in San  
          Francisco, this bill would require landlords to 'stay in the  
          business' for five years before being able to sell or convert  
          the property."

          In response to the above concern, the author writes "landlords  
          have presented no evidence to support this claim.  Advocates who  
          have handled hundreds of Ellis cases have never seen one where  
          the Act was used to avoid landlord bankruptcy.  Landlords are  
          free to sell their buildings.  This bill stops evictions by  
          speculators.  The bill does not stop sale of the property.  With  
          a booming market for rental property in San Francisco, selling  
          rental property is not difficult."  

          The San Diego Apartment Association argues in opposition that  
          "rental property owners have relied on the Ellis Act in order to  
          avoid the potential for bankruptcy or to move into their own  
          rental units?While SB 1439 is specific to San Francisco, it  
          significantly amends the Ellis Act and we fear that such changes  
          will negatively impact rental housing and could eventually make  
          their way to San Diego."  The California Chamber of Commerce  
          echoes these concerns and writes in opposition, "SB 1439 would  
          prevent families who own small rental buildings from, for  
          example, combining two or three small units into a larger one to  
          provide adequate home for a growing family.  In San Francisco,  
          the Ellis Act is often the only way for small property owners to  
          move into their own units."  

          In response, the author writes "The Ellis Act has nothing to do  
          with owner-move-in evictions.  Every jurisdiction with rent  
                                                                      



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          control allows owner-move-in evictions and the Ellis Act is not  
          needed for that." Furthermore, mergers in general are closely  
          monitored by the Planning Commission and discouraged both in the  
          Planning Code and through administrative policies due to the  
          scarcity of rent control housing in San Francisco. Under current  
          regulations, a property owner cannot merge a unit for 10 years  
          after an Ellis Act eviction. A P.O. who uses an OMI to evict a  
          tenant cannot merge for 5 years.


           Support  :  Accela; Advent; Affordable Housing Alliance;  
          AfterCollege, Inc.; Airseed; Alliance for a Better District 6;  
          Apcera; AppMesh Inc.; Asian Americans Advancing Justice - Asian   
          Law Caucus; Asian Pacific Islander Legal Outreach; Asian  
          Southeast Asain Society International Policy Institute; Asian  
          Students Promoting Immingrants Rights Through Education;  
          Automatic Labs Inc.; Babelverse, Inc.; Bay Area Council; Bernal  
          Heights Neighborhood Center; Bill Sorro Housing Program; Box;  
          Brian Webster and Associates; Calle 24 Merchants and  
          Neighborhood Association; California State Association of  
          Counties; California Alliance of Retired Americans; California  
          labor Federation; California Music and Culture Association;   
          California Rural Legal Assistance Foundation; Cause Justa:: Just  
          Cause; Causes; Central City Democrats;; Chinatown Community  
          Development Center; Chinese Chamber of Commerce; Christ Our  
          Redeemer AME Church of Irvine; Cloudera; Community Housing  
          Partnership; Community Tenants Association; Couchsurfing; Crate  
          Labs, Inc.; Credit Karma; Crowdtilt; Data Elite; Deloitte;  
          Emenical Center for Black Church Studies; EchoUser; Events by  
          Vollette; Eviction Defense Collaborative; Expedia Inc.; Exygy;  
          Eyegroove;; Fido Labs; ForageSF; Generator Lab; Getable, Inc.;  
          GitHub; HandUp PBC; Home Ownership San Francisco; Housing Rights  
          Committee of San Francisco; iCloud; Inside; Jawbone; Jesse  
          Miranda Center for Hispanic Leadership; Keen IO; Kite Solutions,  
          Inc.; Lit Motors; Los Angeles Latino Chamber of Commerce; Lower  
          24th Street, Merchants & Neighbors Association; McElroy, Most  
          Reverend Robert W., Auxiliary Bishop of San Francisco;  
          Mesosphere, Inc.; Mission Cultural Center for Latino Arts;  
          Mission Economic Development Agency; Nashville West Studios;  
          National Asian American Coalition; National Housing Law Project;  
          Neighborland; Newsle, Inc.; Non-Profit Housing Association of  
          Northern California; North of Market Business Association;  
          Optimizely; Organizer; Path; Peers; Peerspace; PLAE, Inc.;  
          Project Homeless Connect; QuickPay; RivalMe Inc.; Salesforce;  
          San Francisco Board of Supervisors; San Francisco Building and  
          Construction Trades Council; San Francisco Citizens Initiative  
                                                                      



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          for Technology and Innovation; San Francisco Community Land  
          Trust; San Francisco Housing Development Corporation; San  
          Francisco Interfaith Council; San Francisco Labor Council; San  
          Francisco Latino Democratic Club; Social Bet, Inc.; Silicon Bet,  
          Inc.; Splice vine; Square Trade; StartUpers; St. Anthony  
          Foundation; SV ANGEL; Tagged; Tenant Associations Coalitions of  
          San Francisco; Tenderloin Housing Clinic; Tennis Round, Inc.;  
          TinyCo; TMG Partners; TRAIL; Treasure Island Homeless  
          Development Initiative; Trulia; Twilio; Twitter; Urban Counties  
          Caucus; WEbTalk; West Bay Housing Corporation; Western Center on  
          Law and Poverty; Xoom Corp; YELP; YouBetMe; Zackees, Inc.;  
          Zynga; a number of individuals

           Opposition  :  Apartment Association, California Southern Cities;  
          Apartment Association of Orange County; California Apartment  
          Association; California Association of Realtors; California  
          Chamber of Commerce; Civil Justice Association of California;  
          East Bay Rental Housing Association; NorCal Rental Property  
          Association; San Diego County Apartment Association; San  
          Francisco Association of Realtors; Numerous individuals via  
          petition

                                        HISTORY
           
           Source  :  San Francisco Mayor Edwin M. Lee; Tenants Together

           Related Pending Legislation  : None Known

           Prior Legislation  :  SB 464 (Kuehl, 2007) would have limited the  
          ability of a rental property owner to exercise its "Ellis Act"  
          rights to cases where the owner has owned the property for at  
          least five years.  This bill was placed on the Senate inactive  
          file at the request of the author. 

           Prior Vote  :  Senate Transportation and Housing (Ayes 6, Noes 4)

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