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Cruz v. Ayromloo
No. BC 303634 (Cal. Super. Ct. Los Angeles County Sept. 15, 2005) ; Clearinghouse Number: 55733
Description
Tenants Who Received Relocation Benefits Following Order to Vacate Unsafe Building Retain Possessory Interest; Court Awards Damages
Abstract
The court ruled after trial that plaintiffs—tenants who were
subject to an emergency order to vacate their apartments due to
unsafe conditions and who received relocation benefits from the
landlord—were entitled to return once the building was
repaired. Because the units had been rerented to new tenants, the
court ordered defendant landlord to pay hundreds of thousands of
dollars in damages. Plaintiffs were ordered to vacate with only
hours’ notice after a city inspector found the building
unsafe because raw sewage was leaking under the building and a
portion of the roof was in immediate danger of collapse. Plaintiffs
were never advised that the building was ready for their return and
occupancy. Instead defendant rented to new tenants at increased
rents. Plaintiffs sued for forcible detainer, wrongful eviction,
breach of quiet enjoyment, infliction of emotional distress, breach
of contract, and unlawful business practices and to quiet title.
The court found credible evidence that plaintiffs asked for their
units back and that defendant’s failure to allow
plaintiffs’ return was a forcible detainer; it also ruled for
plaintiffs on wrongful eviction and negligent infliction of
emotional distress. The court rejected defendant’s contention
that the city’s order to vacate and for defendant to pay
relocation benefits ended the tenancies; to rule otherwise, the
court said, would be to allow a landlord, by making a building so
uninhabitable as to force the city to issue an emergency order to
vacate, to circumvent the rent stabilization ordinance and
landlord’s obligations to recover property only through an
unlawful detainer action. Evidence showed that defendant paid
$40,000 in relocation benefits but was receiving $20,000 more in
annual rent from the new tenants, thus recouping the relocation
benefits in two years.
