City of West Hollywood v. 1112 Investment Co

In City of West Hollywood v. 1112 Investment Co. (2003) 105 Cal.App.4th 1134, appellant city filed suit against property owners in June 2000 seeking injunctive relief to prohibit the owners from collecting rents authorized by the city's rent control ordinance and requiring the owners to refund to tenants excess rent collected since 1999. (Id. at p. 1141.) After the trial court granted summary judgment for the property owners, the Legislature amended the Civil Code to eliminate an exemption to local rent control ordinances that previously applied to the property at issue. (City of West Hollywood at p. 1142.) The main issue in the case was whether the amendment simply clarified existing law or, as the court concluded, constituted a change in the law. (Id. at p. 1143.) The court reasoned that "to apply the amendment to the Civil Code to respondent owners in this case would substantially change the legal consequences of their past actions: the rents they charged in previous years. In other words, were we to accept City's invitation to apply the amendment to this case, we would be giving the amendment retrospective effect. The Legislature did not indicate its intent to do that." (Id. at p. 1145.)