Sawday v. Vista Irrigation Dist

In Sawday v. Vista Irrigation Dist. (1966) 64 Cal.2d 833, the lessee - in that case, the party with the interest in changing the rent structure - requested a rent reduction in 1953, but did not initiate arbitration at that time. ( Id. at pp. 834-835.) In 1960, the lessee demanded arbitration of the rent reduction issue for the period from 1950 through 1960. ( Id. at p. 835.) The Supreme Court affirmed the Court of Appeal's decision that the claim for rent reduction prior to 1959 (i.e., six years) was barred because an unreasonable time had passed between accrual of the claim and the demand for arbitration. ( Sawday, supra, 64 Cal.2d at pp. 836-837.) The court also held that the claim for rent reduction from 1959 to 1960 could proceed, because that delay was not unreasonable and plaintiff had not waived her right to arbitration. ( Id. at p. 837.) The claims in Sawday were based on a request for changes to rent rates. The lease in Sawday did not include any specific time frame for requesting the rate change or for demanding arbitration. Thus, in Sawday, a change in the rent could be requested at any time throughout the course of the lease.