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HomeMy WebLinkAboutCORRESPONDENCE - 85BCity Council Meeting Correspondence 12/4/2018 OPTIONS ON HOUSING SOLUTIONS AND CONSIDERATION OF JUST CAUSE EVICTION ORDINANCE; AND NEXT STEPS REGARDING HOMELESS EFFORTS, THE LINK, AND PERMANENT SHELTER WITH COUNTY — MAYOR PRO TEM MARTINEZ AND COUNCILMEMBER BENAVIDES 11 12%4/2018 Sandra Ortega Clergy and Laity United for Yes Economic Justice 12 1214/2018 Ugochi Anaebere- Public Law Center Yes Nicholson e e 11 1 12/3/2018 Matthew Buck California Apartment Yes Yes Association *RA - Recommended Action Wednesday, December 05, 2018 Page 1 of 2 Date of Name Representative of In Favor In Opposition Comment Correspondence of RA*. of RA.* 2 121412018 Leonel Velazquez Orange County Yes Rodriguez Congregation Community 3 12/4/2018 Sandra Esmeralda De OCIYU Yes Anda 4 1214/2018 Karen Romero Estrada Orange County Community Yes Organized for Responsible 5 12/4/2018 Hilda Ortiz on behalf of Latino Health Access Yes Nancy Mejia 6 121412018 Isuri S. Ramos on behalf The Kennedy Commission Yes of Cesar Covarrubias 7 1214/2018 Isun S. Ramos on behalf The LGBT Center OC Yes of Luis Gomez for Laura 8 121412018 Vecindario Lacy on Accion Yes (VeLA) 9 12/4/2018 Alexis Teodoro on behalf Santa Ana Building Healthy Yes of Ana Urzua Communities 10 12/4/2018 Luis Sarmiento Centro Cultural de Mexico Yes 11 12%4/2018 Sandra Ortega Clergy and Laity United for Yes Economic Justice 12 1214/2018 Ugochi Anaebere- Public Law Center Yes Nicholson e e 11 1 12/3/2018 Matthew Buck California Apartment Yes Yes Association *RA - Recommended Action Wednesday, December 05, 2018 Page 1 of 2 Date of Name Representative of In Favor In Opposition Comment Correspondence of RA*, of RA.* . 1 TOTAL: 12 *RA - Recommended Action Wednesday, December 05, 2018 Page 2 of 2 Orozco, Norma From: Huizar, Maria Sent: Monday, December 03, 2018 3:40 PM To: eComment Subject: ECOMMENT: Agenda Item 85B - Just Cause Evictions Attachments: Just -Cause -CAA white paper.pdf, CAA Just Cause Letter to Santa Ana Council_ 120418.pdf, 85B -Just Cause Eviction Ordinance.doc Mayor and City Council, Attached is communication received on Agenda Item 85B that is on your agenda for consideration tomorrow. Also included is the ordinance that corresponds to item for your review and information. From: Matt Buck [ Sent: Monday, December 3, 2018 3:06 PM To: Huizar, Maria <MHuizar@santa-ana.org> Cc: Godinez, Raul <RGodinez@santa-ana.org> Subject: Letters to City Council from CAA: Just Cause Evictions Hi Maria, Please help me provide our position letter and white paper on 'Just Cause' evictions to the Mayor and Council for the council meeting tomorrow. Thank you in advance. Sincerely, Matt Matthew Buck - Vice President of Public Affairs California Apartment Association 23436 Madero Road, Suite 240 Mission Viejo, CA 92691 N December 4, 2018 The Honorable Miguel Pulido Mayor, City of Santa Ana 22 Civic Center Plaza Santa Ana, CA 92701 Re: CAA Opposes `Just Cause' Eviction Policies Dear Mayor Pulido and Council Members: The California Apartment Association, Orange County Division, which represents more than 100,000 units throughout Orange County, applauds the city for being vigilant in exploring ways to promote ethical housing management practices throughout the City of Santa Ana. However, we are strongly opposed any form of `just cause' eviction policies on rental housing units. While well intentioned, `just cause' eviction ordinances can become the bane of neighborhood leaders seeking to rid a community from the impacts of a renter converting a home to a "gang house" or "drug den," where surrounding neighbors fear the prospect of testifying or offering declarations in support of an eviction proceeding. In addition to a myriad of unintended consequences, the State of California already has some of the most aggressive tenant rights laws in the nation. What are `Just Cause' Eviction Policies Most elected officials and members of the community are familiar with the concept of rent control and have a basic understanding of the ways in which it impacts the local economy. Less well known and understood is the companion to rent control, so-called "just cause" eviction. `Just cause' eviction ordinances take away a landlord's right to terminate a tenancy or refuse to renew a lease for any reason or no reason at all. The contents of this letter cover the effect of `just cause' eviction ordinances within neighborhoods, broader communities and local jurisdictions. `Just Cause' Eviction Policies are Unnecessary State Law Prohibits Retaliatory Evictions Both the common law and California Civil Code section 1942.5 prohibit a landlord from seeking to evict or otherwise taking adverse actions against a tenant because the tenant has engaged in a legally protected activity (which includes complaining about habitability issues). In fact, Civil Code Section 1942.5(a) provides greater protection than most `just cause' eviction ordinances because it establishes a presumption in favor of the tenant, stating that the landlord may not act to evict a tenant within 180 days after the tenant complains to the landlord or a government agency about habitability. The California anti -retaliation laws function as both a defense to an unlawful detainer action and as a basis for an affirmative lawsuit. California Apartment Association Orange County 23436Madero Road, Suite240 ` Mission Viejo, CA 92691 949.955.3695. caanet.org December 4, 2018 The Honorable Miguel Pulido Mayor, City of Santa Ana 22 Civic Center Plaza Santa Ana, CA 92701 Re: CAA Opposes `Just Cause' Eviction Policies Dear Mayor Pulido and Council Members: The California Apartment Association, Orange County Division, which represents more than 100,000 units throughout Orange County, applauds the city for being vigilant in exploring ways to promote ethical housing management practices throughout the City of Santa Ana. However, we are strongly opposed any form of `just cause' eviction policies on rental housing units. While well intentioned, `just cause' eviction ordinances can become the bane of neighborhood leaders seeking to rid a community from the impacts of a renter converting a home to a "gang house" or "drug den," where surrounding neighbors fear the prospect of testifying or offering declarations in support of an eviction proceeding. In addition to a myriad of unintended consequences, the State of California already has some of the most aggressive tenant rights laws in the nation. What are `Just Cause' Eviction Policies Most elected officials and members of the community are familiar with the concept of rent control and have a basic understanding of the ways in which it impacts the local economy. Less well known and understood is the companion to rent control, so-called "just cause" eviction. `Just cause' eviction ordinances take away a landlord's right to terminate a tenancy or refuse to renew a lease for any reason or no reason at all. The contents of this letter cover the effect of `just cause' eviction ordinances within neighborhoods, broader communities and local jurisdictions. `Just Cause' Eviction Policies are Unnecessary State Law Prohibits Retaliatory Evictions Both the common law and California Civil Code section 1942.5 prohibit a landlord from seeking to evict or otherwise taking adverse actions against a tenant because the tenant has engaged in a legally protected activity (which includes complaining about habitability issues). In fact, Civil Code Section 1942.5(a) provides greater protection than most `just cause' eviction ordinances because it establishes a presumption in favor of the tenant, stating that the landlord may not act to evict a tenant within 180 days after the tenant complains to the landlord or a government agency about habitability. The California anti -retaliation laws function as both a defense to an unlawful detainer action and as a basis for an affirmative lawsuit. Tenants Have Additional Protections Under Existing Law Existing law already provides many protections for the most vulnerable people in our society — low income, elderly, and disabled tenants in the eviction process. Some of these protections apply to all tenants. For example, landlords are held to a very strict standard in eviction cases. The smallest error, such as an inverted number in an address on a termination notice can cause a landlord to lose an eviction case even though the tenant may not have been misled by the mistake. In addition, the unlawful detainer process itself contains several built-in protections for tenants. For instance, when a landlord files an unlawful detainer action against a tenant, the court is required to send a "Notice of Filing of Unlawful Detainer" to the tenant. This notice contains, among other things, the name and telephone number of a legal services organization that provides legal services (typically free of charge) to low-income persons in the county. Other protections specifically target vulnerable populations. For example, landlords' duties to reasonably accommodate disabled tenants may include giving a disabled tenant additional time, beyond the 30 or 60 days provided for in the law to move out. Section 8 tenants have a statutory right to 90 days' notice when their lease is not being renewed or their tenancy is otherwise being terminated through no fault of their own. Tenants in other subsidized housing are already provided protection from no -cause evictions under the rules of the subsidy programs. In addition to these protections, the law gives judges who preside over unlawful detainer cases two powerful tools to assist tenants who have hardships. First, judges have discretion to stay the execution of an unlawful detainer judgment — which has the effect of delaying the lock -out — by up to 40 days after judgment is entered. Second, in cases of serious hardship, the judge has the discretion to grant a "motion for relief from forfeiture." The effect of this ruling is to restore the tenancy, thereby sparing the tenant from eviction. Because this remedy is limited to cases of hardship, it provides a valuable "safety valve" for the truly vulnerable without allowing intransigent tenants to avoid eviction despite their bad behavior. These are just a handful of examples at how California law currently protects tenants. `Just Cause' Eviction Laws Hurt Tenants Good Tenants Get Stuck with Bad Neighbors Due to the amount of evidence required to complete a `for cause' eviction, it takes months if not years to evict a bad tenant. Successful removal requires landlords to give bad tenants multiple written warnings, and to document the on-going issues with objective evidence (photos, security footage, tenant complaints, police involvement). Neighboring tenants suffer during this time as they're forced live with the bad tenant's behavior. The list of horror stories is endless. Tenants Receive Less Notice Landlords rarely terminate the tenancy of residents who pay the rent and comply with the lease. More often than not, a landlord serves a `no cause' termination notice in response to a tenant's violation of the lease. While the landlord could pursue a `for cause' notice, it is easier to give a 30/60 -day notice. So, under a `just cause' ordinance, landlords aren't going to stop evicting bad tenants, they will simply start issuing 3 -day notices versus 30/60 -day notices. Negative Impact on Tenants' Rental History As mentioned above, `just cause' ordinances result in more 3 -day notices being served. Being served with a 3 -day notice is a negative mark on a tenant's rental history, whereas being served with a 30/60 -day notice is not necessarily. This is because 30/60 -day notices can be served for reasons unrelated to the tenant (such as owner move -in or renovation). CAA's Rental Applicant Reference Form asks if a tenant has ever been served with a 3 -day notice but does not ask if a 30/60 -day notice was served. Under a `just cause' ordinance more tenants will have the negative mark of having been served with a 3 -day notice. This will negatively impact tenants' abilities to find new housing. More Unlawful Detainer Actions Will be Filed It's nearly impossible to find a new place to live, pack, and move in 3 days, tenants are more likely to stay in the unit after the expiration of a 3 -day notice versus a 30/60 -day notice. Thus, it is more likely that tenants will have an unlawful detainer action filed against them. Having a UD judgment on your rental history makes it nearly impossible to get approved for new rental housing. Tenants More Likely to Have to Page Attorney's Fees Awards Many courts have attorney fee schedules that limit the amount of attorney's fees that can be awarded in unlawful detainer actions (often it is limited to a flat $500 or $750). However, if the case was more complicated, the court generally has discretion to award a higher amount. Because `for -cause' cases take more work to prove, landlords are more likely to be able to obtain higher awards which tenants have to pay. The average `for -cause' case that results in a pre-trial settlement incurs nearly $5,000 in attorney fees. However, in nuisance cases that went to trial it's not unusual for the fees to approach $15,000420,000. Most leases have an attorney's fee provision, which makes the tenants responsible for paying the landlord's costs to go to court. More Critical Landlords `For -cause' cases take a lot of evidence to prove. It is helpful to be able to show a long pattern of misbehavior in support of a case. Thus, tenants are more likely to be under a microscope when the landlord is subject to `just cause' requirements. Every rule violation will result in lease violation notices being served and every minor incident will be documented in tenants' files. Tenant advocates might say that this is a good thing because landlords should have to document and give warnings, but many tenants say they felt like the practices are too much. Conclusion As I have highlighted throughout this letter, there's an overwhelming amount of evidence that shows why `just cause' eviction ordinances are not appropriate solutions to a community's housing issues. Not only do they impede a rental housing provider's progress in providing quality rental housing, such ordinances are legally unnecessary and ultimately hurt tenants. CAA thanks you for allowing us to be a resource to the City of Santa Ana, please do not hesitate to contact us on any issues related to rental housing policy or if you have any questions on the contents of this letter. I can be reached directly at 951-809-4423 or MBuck@caanet.org. Sincerely, Matthew Buck Vice President of Public Affairs California Apartment Association Cc: Mayor Pro Tem Michele Martinez Councilmember Vicente Sarmiento Councilmember Jose Solorio Councilmember David Benavides Councilmember Juan Villegas Councilmember Sal Tinajero Just Cause Eviction Eviction Control Measures Throughout California Cities Most rental housing owners and managers are familiar with the concept of rent control and have a basic understanding of the ways in which it impacts their business. Less well known and understood is the companion to rent control, so-called "just cause" eviction. Though the "just cause" name may make these laws sound innocuous, they would be more aptly referred to as eviction control. In essence, just cause eviction ordinances take away a landlord's right to terminate the tenancy or refuse to renew a lease for any reason or no reason at all. These laws also generally require the landlord to pay relocation assistance to tenants whose tenancies are terminated through no fault of their own. Increasingly, these laws also limit the landlord's ability to change the terms of the tenancy, and they control who can live in the rental unit. This paper will discuss the effect of just cause eviction ordinances on the rental housing industry and will discuss the common themes seen in just cause eviction ordinances throughout California. I Typical Provisions in Just Cause Ordinances A. Applicability There is significant variation among just cause eviction ordinances on the issue of which units within the city are subject to the requirements of the ordinance. For example, the City of San Diego (which has just cause eviction but not rent control) applies to all unsubsidized rental units if the tenant has lived in the unit for two years or longer. By contrast, the City of Mountain View's just cause eviction protections apply only to properties with three or more units with a certificate of occupancy issued on or before April 5, 2017, without regard to how long the tenant has lived in the unit. The Costa -Hawkins Rental Housing Act, which places restrictions on the type of rental units local governments may subject to rent control and limits the provisions of rent control measures, does not govern just cause ordinances/eviction controls. As a result, in cities with rent control, it is common for both rent controlled and non -rent -controlled units to be subject to the city's just cause eviction rules. Therefore, owners and managers cannot assume they are exempt from a just cause eviction ordinance simply because they are not subject to rent control. B. Permissible Reasons for Eviction All just cause eviction ordinances list the reasons, or "causes," for which the landlord may terminate the tenancy. Most of the permitted causes relate to something that a tenant did or failed to do, but there are a limited number of "no fault" reasons that a tenancy may be terminated. The most common permissible reasons for eviction are: California Apartment Association www.coonet.org Revised 06/2017 — O 2017 — All Rights Reserved Cage 1 121 1. Non -Payment of Rent; 2. Material Violation of the Rental/Lease Agreement; 3. Substantial Damage to the Rental Unit; 4. Nuisance; 5. Criminal/Unlawful Activity; 6. Refusing Access to the Unit; 7. Refusal to Agree to a New Rental/Lease Agreement with Substantially Similar Terms; 8. Substantial Rehabilitation of the Unit; 9. Owner Move -In; 10. Demolition; 11. Withdrawal of all the Rental Units on the Parcel from the Rental Market (Ellis Act). C. Restrictions on the Permissible Reasons for Eviction The above listed most -common permissible reasons for eviction appear on their face to be broadly applicable. However, the provisions of the individual just cause eviction ordinances typically narrowly define or otherwise restrict an owner's ability to invoke a permissible ground to complete an eviction. The most common restrictions on the permissible reasons for eviction are discussed below. D. Prior Written Warning Just cause eviction ordinances usually require that a tenant be given a prior written warning (often referred to as a "written notice to cease") before a tenant's violation of the lease or other offending conduct, such as damaging the property or refusing access to the unit, may serve as the basis for eviction. For certain types of conduct, the warning requirement may also require the landlord to offer the tenant additional ways to avoid eviction despite their bad conduct. For example, the just cause eviction ordinance in Oakland states that a landlord may only evict a tenant who willfully and substantially damages the rental unit after: (1) the tenant has been given a written notice to cease, and (2) the tenant has refused to cease damaging the premises or has refused to either make satisfactory correction or to pay the reasonable costs of repairing such damage "over a reasonable period of time." In effect, this provision means that a landlord is required to offer a tenant a payment plan to pay for repairs to correct damage that the tenant willfully caused and so long as the tenant agrees to the payment plan and to not willfully damage the property again, the landlord cannot evict. E. Certain Breaches of the Lease Excluded Though breach of the lease by the tenant is listed as a permissible reason for eviction in just cause eviction ordinances, the landlord's ability to evict for certain types of breaches is curtailed by many just cause ordinances. The most common limitation relates to the landlord's ability to control who may live in the unit. There are different variations on this type of restriction. The most common provisions provide that a landlord cannot evict a tenant for violating a lease provision against subleasing if: (1) the tenant continues to reside in the unit, (2) the sub -lessee is replacing a departed roommate on a one-to-one basis, and (3) the landlord has "unreasonably withheld" the right to sublease. Some ordinances provide that a landlord may not deny permission to sublease based on the proposed sub -lessee's lack of creditworthiness. It is also becoming increasingly common for just cause eviction ordinances to prohibit a landlord from evicting a tenant who has allowed specified family members (including children, parents, grandchildren, grandparents, siblings, and spouses or domestic partners of such family members) to occupy the unit, despite any limitations in the lease on the number of occupants or requirements that new occupants must first apply and be approved. California Apartment Association www.caanet.arg Revised 0512017— © 2017— All Rights Reserved I� Page 2 In addition to the limitations on occupancy, many just cause eviction ordinances limit a landlord's ability to evict a tenant based on the breach of a lease provision which was not part of the original rental/lease agreement. Specifically, these provisions typically state that a landlord cannot evict a tenant for violation of a lease provision which was not part of the original rental/lease agreement unless the landlord first notified the tenant that he or she need not accept the newly added lease provision. F. "No Fault" Eviction Protections for Elderly and Disabled Tenants Some just cause eviction ordinances prohibit a landlord from using owner move -in as the basis for the eviction of a tenant who is either elderly or disabled. Many just cause eviction ordinances also require that elderly and disabled tenants be given one year's notice to move out when the eviction is based on withdrawal of the unit from the rental market. Some ordinances also provide for additional relocation payments to elderly and disabled tenants. A tenant is generally defined as being "elderly" if he or she is sixty-two years of age or older. However, at least one ordinance, enacted by the City of Oakland, lowers the age threshold to sixty years of age. These provisions also typically adopt the very broad definition of "disability" found in the Fair Employment and Housing Act (FEHA), which includes any physical or mental disease, disorder, or condition which "limits a major life activity." This definition of "disability" may include mental disorders such as depression. G. Payment of Relocation Assistance Most just cause ordinances require the landlord to pay relocation assistance to tenants who are evicted for a "no fault" reason, such as owner move -in or permanent removal of the unit from the rental market. The required amount of the relocation assistance varies from city to city. The relocation payment typically includes all of the following: (1) refund of the security deposit without deduction or offset, (2) a payment equivalent to a specified number of months' rent for a comparable rental unit at the market rate, and (3) a specified amount of moving expenses. These payments often cost $10,000 or more per unit. H. First Right of Refusal A tenant who is evicted for a permissible "no fault" reason (such as owner move -in, Ellis Act, demolition, or substantial repair) under a just cause eviction ordinance is usually entitled to a first right of refusal to re -rent the rental unit if it is returned to the rental market. Some ordinances limit the first right of return to a specified period of time. For example, San Francisco's just cause ordinance requires that if an owner terminates a tenancy to perform an owner move -in, but then returns the unit to the rental market within three years, the owner must offer to re -rent the unit to the tenant who was displaced. Other ordinances, such as the City of Richmond's just cause eviction ordinance, gives the tenant, whose tenancy is terminated to allow an owner move -in, substantial repair, or withdrawal of the unit from the market (Ellis Act), the first right of refusal to re -rent the unit at the same rental rate in place at the time of eviction if the rental unit is ever returned to the rental market. I. Other Requirements Most just cause eviction ordinances require the landlord to file copies of any notice of termination and/or any unlawful detainer summons and complaint with the city within a relatively short period of time after they are served on the tenant. In addition, many ordinances include various requirements that the landlord make certain statements or certifications in their notices to tenants and in their unlawful detainer complaint. For example, the just cause eviction ordinance in the City of Richmond requires that any written notice served on the tenant as a result of the tenant's breach of their lease, nuisance conduct, or failure to give access must inform the tenant of their right to request a reasonable accommodation. The California Apartment Association www.coonet.org Revised 06/2017 — 02017— All Fights Reserved Page 3 121 City of East Palo Alto's just cause eviction ordinance includes a requirement that the landlord must allege compliance with the warranty of habitability as part of their unlawful detainer action for any eviction other than evictions based on substantial repair of the rental unit or withdrawal of the unit from the rental market. J. Remedies for Non -Compliance Just cause eviction ordinances typically provide that a landlord's alleged failure to comply, in any way, with the ordinance is a complete defense to an unlawful detainer action (meaning that the landlord would have to start over if found to have violated the provisions of the just cause ordinance). Some ordinances also provide for civil (including injunctive and monetary relief) and criminal penalties for non-compliance by the landlord. II Practical Effect of Just Cause Eviction Ordinances Just cause eviction ordinances are often described as simply requiring landlords to provide a valid reason why they are evicting the tenant when they serve a notice terminating the tenancy. The arguments relied upon by tenant advocates in support of just cause evictions ordinances often relate to the need to protect tenants from retaliatory eviction or evictions motivated by the landlord's desire to increase the rent. These explanations and arguments are misleading. Aside from the fact that just cause eviction ordinances usually include onerous requirements beyond merely requiring the landlord to have cause to terminate the tenancy (as discussed above), simplified explanations of just cause eviction requirements fail to account for the fact that for -cause evictions are substantially more difficult and expensive to complete. Similarly, arguments that just cause ordinances protect tenants from retaliatory eviction and prevent landlords from evicting tenants to raise the rent are simply untrue. A. The Cost of Just Cause As discussed above, just cause eviction ordinances frequently require that landlords' notices to tenants meet very specific requirements. These requirements can include advising tenants of their rights and making specific statements in the notices to tenants. Complying with these procedural requirements can be challenging for landlords because, often, cities do not offer comprehensive resources to help landlords comply with the ordinance. The ordinances themselves tend to be written in dense, vague, and difficult to understand language. As a result, landlords often must retain, at their own expense, an attorney to assist with the preparation and service of both warning and termination notices. These procedural requirements, together with the direct costs (such as relocation assistance) imposed by just cause ordinances substantially increase the cost of terminating a tenancy before even considering the costs of actually litigating a for -cause eviction. For -cause evictions are significantly more difficult and expensive because the landlord has the burden of proving, with evidence, that sufficient cause exists to terminate the tenancy. This may sound simple in theory, but it is not always so simple in practice. Some for -cause evictions are more difficult than others. For example, most non-payment of rent evictions are relatively straight forward, although such cases can be complicated by allegations that the unit is uninhabitable. On the other hand, evictions based on nuisance and illegal activity are perhaps the most difficult because, in most cases, the landlord must rely on reluctant third parties (neighbors and/or law enforcement) to provide the evidence necessary to win the eviction case. Contrary to what one might expect, the more serious the problem with a tenant, the more difficult it is to evict. The neighbors of drug -dealing or gang -affiliated tenants often complain anonymously to the landlord, but then refuse to make written statements or testify in court out of fear that they will be retaliated against by their bad -news neighbor. While a landlord's attorney can subpoena these neighbors to appear at the eviction trial, a subpoena cannot compel a scared neighbor to testify California Apartment Association www.coonet.org Revised 06/2017 — O 2017 — All Rights Reserved Page 4 112t truthfully. The problem is compounded further when there are numerous tenants engaged in illicit activity because even though it is plain to any observer that there is an issue, the problematic tenants protect each other. Local law enforcement is often of little help. Even if the police do respond to calls, they often do not make arrests, or if they do, the offending tenant is released shortly thereafter. Most police departments also will not release police reports to landlords, even if the incident occurred on the landlord's property. In areas without just cause requirements, landlords have a tool to address these issues. Such problematic tenants can be served a 30 or 60 day "no cause" termination notice. But in areas with just cause requirements, landlords are deprived of this tool and must either convince tenants to testify, or tolerate a tenant who creates a nuisance. If the landlord is able to obtain the evidence to prove that a permissible cause exists to terminate the tenancy, then there is the issue of presenting that evidence to the court. Though unlawful detainer actions are often heard by the same judges that hear small claims cases, unlawful detainer actions are not small claims cases. They are civil law suits that are subject the same rules governing presentation and admissibility of evidence that are applicable to other civil cases. In addition, unlawful detainer trials are often placed on crowded court calendars with other unlawful detainer trials. The judges who oversee these cases must handle many cases in a short period of time, and they expect landlords who choose to represent themselves to be able to present their case in an efficient manner, in accordance with the rules of evidence. Because of the complex rules governing admissibility, presentation of evidence, as well as the inherent pressures of the courtroom, and the skill (gained from experience) necessary to effectively present evidence and question witnesses, most landlords are not equipped to effectively represent themselves in a for -cause unlawful detainer action. Keeping an attorney experienced in handling for - cause evictions on retainer is an expensive, but necessary, reality for landlords in areas with just cause eviction ordinances. III Just Cause Eviction is an Unnecessary Policy A. State Law Prohibits Retaliatory Evictions Tenant advocates often argue that just cause eviction policies are necessary to protect tenants from being evicted as a result of their complaints about substandard conditions. However, California law already provides protections against retaliatory evictions, regardless of whether the unit is subject to a just cause eviction ordinance. Both the common law and California Civil Code section 1942.5 prohibit a landlord from seeking to evict or otherwise taking adverse actions against a tenant because the tenant has engaged in a legally protected activity (which includes complaining about habitability issues). In fact, Civil Code Section 1942.5(a) provides greater protection than many just cause eviction ordinances because it establishes a presumption in favor of the tenant if the landlord acts to evict the tenant within 180 days after the tenant complains to the landlord or a government agency about habitability. The California anti -retaliation laws function as both a defense to an unlawful detainer action and as a basis for an affirmative lawsuit. B. Being Evicted to Raise the Rent Is a Fallacy The second most popular argument advanced by tenant advocates in favor of just cause eviction is that it protects tenants from being evicted by "greedy" landlords who want to raise the rent. This argument does not hold water. First, this argument ignores the fact that it is rent control policies (which often go hand-in- hand with just cause eviction policies) that are responsible for the landlord's inability to raise the rent to market during the tenancy. But for a rent control ordinance, landlords would not need the unit to be vacant in order to raise the rent to keep up with increased costs. More importantly though, not only do just cause eviction ordinances not provide a solution for the non-existent problem of no -cause evictions being motivated by a desire to raise the rent, they actually do the opposite. Under California law, cities California Apartment Association www.caonet.org Revised 06/2017 — © 2017 — All Rights Reserved Page 5 12t with rent control ordinances are generally prohibited from enforcing vacancy control (controlling the rent charged at the beginning of the tenancy). However, an exception exists which allows a city to control the rent charged at the beginning of the tenancy where the landlord terminated the preceding tenancy with a 30 or 60 day notice (i.e. without cause or for a "no fault" reason). No such exception exists where the previous tenant was evicted based on something he or she did or failed to do (i.e. where the tenant was at fault). This means that if the hypothetical greedy landlord really did want to evict a tenant in order to raise the rent, they would have to be able to show that the tenant failed to pay rent, breached the lease, was a nuisance, or was otherwise at fault — all of which are permissible grounds for eviction under just cause eviction ordinances. C. Tenants Have Additional Protections Under Existing Law Just cause eviction policies are often promoted as necessary to protect the most vulnerable people in our society — low income, elderly, and disabled tenants. However, existing law already provides many protections for such individuals in the eviction process. Some of these protections apply to all tenants. For example, landlords are held to a very strict standard in eviction cases. The smallest error, such as an inverted number in an address on a termination notice can cause a landlord to lose an eviction case even though the tenant may not have been mislead by the mistake. In addition, the unlawful detainer process itself contains several built-in protections for tenants. To begin with, when a landlord files an unlawful detainer action against a tenant, the court is required to send a "Notice of Filing of Unlawful Detainer" to the tenant. This notice contains, among other things, the name and telephone number of a legal services organization that provides legal services (typically free of charge) to low-income persons in the county. The Judicial Council, the policymaking body for the California court system, has created a "check the box" form that tenants who represent themselves in unlawful detainer actions can use to respond to an unlawful detainer action. The form includes "check the box" options for tenants to deny the landlord's allegations, and it also lists the ten most common affirmative defenses in unlawful detainer actions. Other protections specifically target vulnerable populations. For example, landlords' duties to reasonably accommodate disabled tenants may include giving a disabled tenant additional time, beyond the 30 or 60 days provided for in the law to move out. Section 8 tenants have a statutory right to 90 days' notice when their lease is not being renewed or their tenancy is otherwise being terminated through no fault of their own. Tenants in other subsidized housing are already provided protection from no -cause evictions under the rules of the subsidy programs. In addition to these protections, the law gives judges who preside over unlawful detainer cases two powerful tools to assist tenants who have hardships. First, judges have discretion to stay the execution of an unlawful detainer judgment — which has the effect of delaying the lock -out — by up to 40 days afterjudgment is entered. Second, in cases of serious hardship, the judge has the discretion to grant a "motion for relief from forfeiture." The effect of this ruling is to restore the tenancy, thereby sparing the tenant from eviction. Because this remedy is limited to cases of hardship, it provides a valuable "safety valve" for the truly vulnerable without allowing intransigent tenants to avoid eviction despite their bad behavior. IV Just Cause Eviction Policies Are Bad for Tenants A. Good Tenants Must Live with Bad Neighbors Just cause policies are not just expensive and harmful for landlords, they actually harm tenants. Paradoxically, the people just cause policies are meant to help — honest, rule abiding tenants — are harmed most. The reason is simple. By making it more difficult to remove bad tenants, good tenants are stuck living with their bad -tenant neighbors during the often long and arduous eviction process, if the bad California Apartment Association www.caanet.org Revised 0612017— O 2017 —All Rights Reserved l� Page 6 tenant can be evicted at all. This leaves good tenants with a Hobson's choice: live with disruptions until the bad neighbor can be evicted or find a new place to live (which likely means paying more in rent). B. Less Notice and Tarnished Rental Histories Those who advocate for just cause policies seem to assume that because "no cause" termination notices can be served for any reason or no reason at all (but not an illegal reason) that landlords do not have reasons for serving such notices. Of course, this isn't generally the case. It is not good business to evict good tenants for no reason. Rather, 30 and 60 day notices of termination notices are generally served for a reason. Sometimes that reason is not related to the tenant's conduct; for example, if the owner plans to move into the unit (which is also allowed underjust cause ordinances). But often, a 30- or 60 -day notice is precipitated by a tenant's bad conduct. For example, a landlord may choose to serve a "no cause" 30 - or 60 -day termination notice to a tenant who is excessively noisy. Even though the landlord could have terminated the tenancy for cause in these circumstances, it is usually more economical for the landlord to serve a "no cause" termination notice in order to avoid the expense and complexity associated with for - cause eviction (discussed above). But it is not just the landlord who benefits from opting to serve a "no cause" 30- or 60 -day termination notice rather than a for -cause 3 -day notice. The tenant receiving the notice also benefits because he or she is allowed substantially more time to find a new place to live, and the tenant also avoids the negative mark on his or her rental history associated with being served a 3 - day notice. An often overlooked benefit of "no cause' termination notices is that because they can be served for any reason or no reason at all (but not an illegal reason), it cannot be presumed that the tenant did or failed to do something that caused their tenancy to be terminated. For this very reason, CAA's Rental Applicant Reference Form (Form 3.7) does not ask whether the tenant was served a 30- or 60 -day notice, but it does ask whether the tenant was served with a 3 -day notice for cause. Because 3 -day notices can only be served as a result of the tenant doing something they were not supposed to do, or failing to do something they were supposed to, so a landlord considering an application can make a negative inference against a tenant who has been served with a 3 -day notice. Because just cause policies take away the landlords discretion to serve a "no cause" termination notice, they have no choice but to use the 3 -day notice procedure to remove tenants who violate the lease. This means that more tenants will end up with negative marks on their rental histories, which will make it more difficult to find new housing in an already tight housing market. The short notice timeframes also make it more difficult for tenants to move out and avoid an unlawful detainer action. Thus, a tenant who is served with a 3 -day notice is more likely to have an unlawful detainer judgment entered against him or her. Many landlords perform unlawful detainer checks as part of their screening procedure and will not accept the application of a person who has had an unlawful detainer judgment entered against them. C. Increased Costs for Tenants Most rental/lease agreements contain some sort of attorney's fees provision which provides that in the event of legal action between the parties, the losing party must pay some or all of the prevailing party's legal fees. These provisions are enforceable in unlawful detainer actions. While these provisions have the benefit of dissuading unscrupulous landlords from filing frivolous cases, they can also result in judgments against tenants that often include hefty attorney fee awards. In cases based upon "no cause" termination notices, this is not often the case because many courts have local rules that limit awards of attorney's fees to a couple hundred dollars in "ordinary" cases. However, because for -cause evictions are not ordinary — they tend to be complex and expensive — the court will award attorney's fees beyond the amount allowed by the local rules. In addition to attorney's fees, the prevailing party is also entitled, by law, to their "costs," which include things like filing fees, process server fees, and legally mandated - witness fees. As a result of these rules, tenants who are evicted for cause may end up with judgments California Apartment Association www.caanet.org Revised 06/2017 — O 2017 — All Rights Reserved Page 7 121 against them for many thousands of dollars, compared to a couple of hundred dollars in a case based upon a "no cause" termination notice. These money judgments affect the tenants' credit, and thus their ability to find new housing. In addition, because evicted tenants are often unable to pay the judgments entered against them, the landlord must increase rents to cover their costs (the landlord has to pay their attorney whether the evicted tenant pays the judgment or not). In effect, this means that good tenants end up paying for the bad conduct of their evicted neighbors. V Cities with Just Cause Eviction Ordinances The cities that currently have just cause eviction ordinances are as follows: • Alameda • Berkeley • Beverly Hills • East Palo Alto • Glendale • Hayward • Los Angeles • Maywood • Mountain View • Oakland • Palm Springs • Richmond • San Diego • San Francisco • San Jose • Santa Monica • West Hollywood Owners and managers of rental units in cities with just cause eviction ordinances should review the ordinance and consult with their attorney prior to beginning any eviction. References 41. U.S.C. § 3601 Civil Code §§ 51, 827, 1942.5, 1954.53 Code of Civil Procedure §§ 918, 1032, 1161, 1179 Government Code § 12900, et seq. City of East Palo Alto Municipal Code § 14.04.160, et seq. City of Mountain View Charter, Article XVI I City of Oakland Municipal Code § 8.22.300, et seq. City of San Diego Municipal Code § 98.0730, et seq. City of San Jose Municipal Code § 17.23.1200, et seq. City and County of San Francisco Administrative Code § 37.9, et seq. City of Richmond Municipal Code § 11.100.010, et seq. Barela v. Superior Court (1981) 30 Cal.3d 244 California Apartment Association www.caanet.org Revised 06/2017 — O 2017 — All Rights Reserved Page 8 112t Orozco, Norma From: Leonel Velasquez Rodriguez < Sent: Tuesday, December 04, 2018 11:45 AM To: eComment; Huizar, Maria Subject: Just Cause Evictions Letter of Support OCCCO Attachments: December 4th, 2018 letter Santa Ana.pdf Categories: Correspondence Hi Maria, I hope I find you wellll l Here's a attachment below for a strong Support of Just Cause Evictions in Santa Ana City. Thank you very much God bless you Leonel Velazquez Rodriguez Immigration and Education Community Coordinator Orange County Congregation Community Organization OCCCO is a non-profit, non-partisan 501(c)3 organization. OCCCO is not aligned with any political party nor do we support candidates for office.CONFIDENTIALITY NOTICE: This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to which they are addressed. If you are not the intended recipient, you may not review, copy or distribute this message. If you have received this email in error, please notify the sender immediately and delete the original message. Neither the sender nor the company for which he or she works accepts any liability for any damage caused by any virus transmitted by this email. @2018 Orange County Congregation Community Organization IMINIoccco•�011e%b together in faith, forward for justice December 4th, 2018 Mayor Pulido and City Councilmembers City of Santa Ana 20 Civic Center Plaza P.O. Bo 1988, M31 Santa Ana. CA 92701 RE: 85B: Support - Just Cause Evictions Ordinance Orange County Congregation Community Organization (OCCCO) is an interfaith -based social justice non-profit 501(c)(3) community organization. We work with and represent congregations and communities in the cities of Anaheim, Costa Mesa, Fullerton, and Santa Ana. Over the past four years, we have engaged voters in 60,000 conversations to pass local and state policies in service of our mission: to develop transformational leaders within diverse, multicultural, interfaith communities who together have the power to shape equitable public policy throughout Orange County. We seek to promote comprehensive solutions to the housing crisis including policies designed to keep tenants housed and further prevent homelessness. This includes protecting tenants from unjust evictions. The Orange County Sheriff Department carried out 2,201 evictions by the from 2011- 2016. We know that the number of evictions is much higher as many evictions go unreported. The City has the ability to implement a Just Cause Evictions Ordinance and provide protections from unjust evictions to its most vulnerable tenants. This ordinance would only permit for tenants to be evicted for the following reasons: 1. Failure to Pay Rent 2. Breach of Lease 3. Nuisance 4. Illegal Purpose 5. Refusal to Execute New Lease 6. Failure to Give Access 7. Subtenant in Sole Possession 8. Owner Move -in 9. Necessary and Substantial Repairs Requiring Temporary Vacancy 10. Withdrawal of the Unit Permanently from Rental Market 11. Government Order 12.Vacating an Unpermitted Rental Unit 1 This ordinance would establish specific reasons for which a tenant can be evicted. It will allow for landlords to evict their tenants when there is a just reason and it will protect tenants from unjust evictions such as retaliatory evictions in response to requests for repairs to their unit and Code Enforcement inspections. Tenants who are displaced by landlord actions such as unjust evictions are faced with unfair burdens. Landlords often require prospective tenants pay the equivalent of three months' rent up front to secure a lease—generally representing the first and last month's rent, and a security deposit. The total accumulated cost imposed on a displaced household generally exceeds $10,000 and can frequently reach $20,000 or greater. Tenants who are older adults, persons with disabilities, or have children incur even higher costs due to their particular circumstances. Low- and moderate -income tenants cannot afford such sudden and costly expenses, and they often experience homelessness as a direct consequence of eviction, which itself imposes further financial, social, health, and emotional costs. The severe financial impacts of displacement on tenants pose a threat to the public health, and safety, and welfare of the residents in the City of Santa Ana. There is an immediate need for tenant protections from unjust evictions. We strongly urge the City Council to support its tenants through the immediate adoption and implementation of a Just Cause Evictions Ordinance. Please feel to contact me at ( if you have any questions. Respectfully, Miguel Hernandez Executive Director, OCCCO 2 Orozco, Norma From: Sandra Esmeralda De Anda < Sent: Tuesday, December 04, 2018 1:53 PM To: Huizar, Maria; eComment Subject: Support Letter for Causa Justa Categories: Correspondence December 4th. 2018 Mayor Pulido and City Councilmembers City of Santa Ana 20 Civic Center Plaza P.O. Bo 1988, M31 Santa Ana, CA 92701 RE: 85B: Support - Just Cause Evictions Ordinance OCIYU: We are an undocumented immigrant youth -led organization that advocates for the rights of undocumented immigrants to live lives free from exploitation and persecution. We seek to promote comprehensive solutions to the housing crisis including policies designed to keep tenants housed and further prevent homelessness. This includes protecting tenants from unjust evictions, from 2011- 2016 there were 2,201 evictions carried out by the Orange County Sheriffs Department. We know that the number of evictions is much higher as many evictions go unreported. The City has the ability to implement a Just Cause Evictions Ordinance and provide protections from unjust evictions to its most vulnerable tenants. This ordinance would only permit for tenants to be evicted for the following reasons: 1. Failure to Pay Rent 2. Breach of Lease 3. Nuisance 4. Illegal Purpose 5. Refusal to Execute New Lease 6. Failure to Give Access 7. Subtenant in Sole Possession 8. Owner Move -in 9. Necessary and Substantial Repairs Requiring Temporary Vacancy 10. Withdrawal of the Unit Permanently from Rental Market 11. Government Order 12. Vacating an Unpermitted Rental Unit This ordinance would establish specific reasons for which a tenant can be evicted. It will allow for landlords to evict their tenants when there is a just reason and it will protect tenants from unjust evictions such as retaliatory evictions in response to requests for repairs to their unit and Code Enforcement inspections. Tenants who are displaced by landlord actions such as evictions are faced with unfair burdens. Landlords often require that prospective tenants pay the equivalent of three months' rent up front to secure a lease—generally representing the first and last month's rent, and a security deposit. The total accumulated cost imposed on a displaced household generally exceeds $10,000 and can frequently reach $20,000 or greater. Tenants who are seniors, persons with disabilities, or have children incur even higher costs due to their particular circumstances. Low- and moderate -income tenants cannot afford such sudden and costly expenses, and they often experience homelessness as a direct consequence of eviction, which itself imposes further financial, social, health, and emotional costs. The severe financial impacts of displacement on tenants pose a threat to the public health, and safety, and welfare of the residents in the City of Santa Ana. M There is an immediate need for tenant protections from unjust evictions. We strongly urge the City Council to support its tenants through the immediate adoption and implementation of a Just Cause Evictions Ordinance. Orozco, Norma From: Karen Romero Estrada < Sent: Tuesday, December 04, 2018 2:59 PM To: eComment; Huizar, Maria Subject: RE: 8513: Support - Just Cause Evictions Ordinance Attachments: 8513 OCCORD_LetterofSupport.pdf Categories: Correspondence OCCORD is submitting a comment for the Agenda item number 85B for today's council meeting on December 411, 2018. Our public comment attached as a PDF file. Please let us know when you have received this message. Thank you, Karen Romero Estrada Research and Policy Analyst NOCCORDngcerr no December 4th, 2018 Mayor Pulido and City Councilmembers City of Santa Ana 20 Civic Center Plaza P.O. Bo 1988, M31 Santa Ana, CA 92701 RE: 8513: Support - Just Cause Evictions Ordinance Our Mission is to bring workers, families and community partners together to organize and advocate for good jobs, strong neighborhoods and an inclusive democracy in Orange County. We seek to promote comprehensive solutions to the housing crisis including policies designed to keep tenants housed and further prevent homelessness. This includes protecting tenants from unjust evictions, from 2011- 2016 there were 2,201 evictions carried out by the Orange County Sheriffs Department. We know that the number of evictions is much higher as many evictions go unreported. The City has the ability to implement a Just Cause Evictions Ordinance and provide protections from unjust evictions to its most vulnerable tenants. This ordinance would only permit for tenants to be evicted for the following reasons: 1. Failure to Pay Rent 2. Breach of Lease 3. Nuisance 4. Illegal Purpose 5. Refusal to Execute New Lease 6. Failure to Give Access 7. Subtenant in Sole Possession 8. Owner Move -in 9. Necessary and Substantial Repairs Requiring Temporary Vacancy 10. Withdrawal of the Unit Permanently from Rental Market 11. Government Order 12. Vacating an Unpennitted Rental Unit This ordinance would establish specific reasons for which a tenant can be evicted. It will allow for landlords to evict their tenants when there is a just reason and it will protect tenants from unjust evictions such as retaliatory evictions in response to requests for repairs to their unit and Code Enforcement inspections. Tenants who are displaced by landlord actions such as evictions are faced with unfair burdens. Landlords often require that prospective tenants pay the equivalent of three months' rent up front to secure a lease—generally representing the first and last month's rent, and a security deposit. The total accumulated cost imposed on a displaced household generally exceeds $10,000 and can frequently reach $20,000 or greater. Tenants who are seniors, persons with disabilities, or have children incur even higher costs due to their particular circumstances. Low- and moderate -income tenants cannot afford such sudden and costly expenses, and they often experience homelessness as a direct consequence of eviction, which itself imposes further financial, social, health, and emotional costs. The severe financial impacts of displacement on tenants pose a threat to the public health, and safety, and welfare of the residents in the City of Santa Ana. There is an immediate need for tenant protections from unjust evictions. We strongly urge the City Council to support its tenants through the immediate adoption and implementation of a Just Cause Evictions Ordinance. Respectfully, Karen Romero Estrada on behalf of: Orange County Community Organized for Responsible Development Orozco, Norma From: Hilda Ortiz < Sent: Tuesday, December 04, 2018 2:56 PM To: eComment; Huizar, Maria Cc: Nancy Mejia Subject: Item 85B Support - Just Cause Evictions Ordinance Attachments: LHA_JustCauseEvictionsOrdinance_Support.pdf Categories: Correspondence Hello, Please see the attached letter of support for item 85B on today's City Council meeting agenda. Please let me know if you have any questions, Thank you, Hilda Ortiz Latino Health Access Latino Health Access :(`�eiry�m4io{j G✓ t t?1IYS L 1 December 4, 2018 Mayor Pulido and Members of the City Council City of Santa Ana 20 Civic Center Plaza P.O. Bo 1988, M31 Santa Ana, CA 92701 RE: 85B: Support -Just Cause Evictions Ordinance Latino Health Access is a non-profit organization working to address and alleviate many of the most detrimental public health issues that exist In Santa Ana. We know that the housing crisis that the city is experiencing is affecting the most vulnerable families tremendously; we see the consequences of lack of accessibility and affordability to decent housing every day. Our promotoras are seeing cases related to housing on a daily basis and are trying to provide support and referrals with very few resources available. As an organization, we have acknowledged and understand the need to promote comprehensive solutions to the housing crisis, including policies designed to keep tenants housed and further prevent homelessness. This includes protecting tenants from unjust evictions. From 2011- 2016 there were 2,201 evictions carried out by the Orange County Sheriff's Department. We know that the number of evictions 1s much higher as many evictions go unreported. The City has the ability to implement a Just Cause Evictions Ordinance and provide protections from unjust evictions to its most vulnerable tenants. This ordinance would only permit for tenants to be evicted for the following reasons: 1. Failure to Pay Rent 2. Breach of Lease 3. Nuisance 4. Illegal Purpose S. Refusal to Execute New Lease 6. Failure to Give Access 7, Subtenant in Sole Possession 8. Owner Move -in 9. Necessary and Substantial Repairs Requiring Temporary Vacancy 10. Withdrawal of the Unit Permanently from Rental Market 11. Government Order 12. Vacating an Unpermitted Rental Unit This ordinance would allow landlords to evict their tenants when there is a just reason. It would protect tenants from unjust evictions such as retaliatory evictions in response to requests for repairs to their unit and Code Enforcement inspections. Tenants who are displaced by landlord actions, such as by evictions, are faced with unfair burdens. Landlords often require that prospective tenants pay the equivalent of three months' rent up front to secure a lease—generally representing the first and last month's rent, and a security deposit. The total accumulated cost imposed on a displaced household generally exceeds $10,000 and can frequently reach $20,000 or greater. Tenants who are seniors, persons with disabilities, or have children Incur even higher costs due to their particular circumstance. PREVENTION EDUCATION ACTION Low- and moderate -income tenants cannot afford such sudden and costly expenses, and they often experience homelessness as a direct consequence of eviction, which itself imposes further financial, social, health, and emotional costs. The severe financial Impacts of displacement on tenants pose a threat to the public health, safety, and welfare of residents in the City of Santa Ana. There is an immediate need for tenant protections from unjust evictions. We strongly urge the City Council to support its tenants through the immediate adoption and implementation of a Just Cause Evictions Ordinance. Sincerely, Nancy Mejia, MSW, MPH Director, Community Engagement& Advocacy PREVENTION EDUCATION ACTION Orozco, Norma From: Isuri Ramos < Sent: Tuesday, December 04, 2018 3:07 PM To: Huizar, Maria; eComment Subject: 85B: Just Cause Evictions Ordinance - Letter of Support Attachments: Kennedy Commission - Just Cause Evictions Ordinance.pdf Please see attached correspondence and confirm receipt. Thank you. Isuri S. Ramos The Kennedy Commission Community Organizer The Kennedy Commission Increasing Orange County's Affordable Housing Opportunities The content of this email is confidential and intended for the recipient specified in this message only. It is strictly forbidden to share any part of this message with any third party, without a written consent of the sender. If you received this message by mistake, please reply to this message and follow with its deletion, so that we can ensure such a mistake does not occur in the future. X December 4th, 2018 Mayor Pulido and City Councilmembers City of Santa Ana 20 Civic Center Plaza P.O. Bo 1988, M31 Santa Ana, CA 92701 RE: 8513: Support - Just Cause Evictions Ordinance The Kennedy Commission is a broad coalition of residents and community organizations that advocates for the production of homes affordable for families earning less than $20,000 annually in Orange County. Formed in 2001, the Commission has been successful in partnering and working with jurisdiction in Orange County to create effective policies that has led to the new construction of homes affordable to lower income working families. We seek to promote comprehensive solutions to the housing crisis including policies designed to keep tenants housed and further prevent homelessness. This includes protecting tenants from unjust evictions, from 2011- 2016 there were 2,201 evictions carried out by the Orange County Sheriffs Department. We know that the number of evictions is much higher as many evictions go unreported, and that a significant number of evictions are carried out without just cause. The City has the ability to implement a Just Cause Evictions Ordinance and provide protections from unjust evictions to its most vulnerable tenants. This ordinance would only permit for tenants to be evicted for the following reasons: 1. Failure to Pay Rent 2. Breach of Lease 3. Nuisance 4. Illegal Purpose 5. Refusal to Execute New Lease 6. Failure to Give Access 7. Subtenant in Sole Possession 8. Owner Move -in 9. Necessary and Substantial Repairs Requiring Temporary Vacancy 10. Withdrawal of the Unit Permanently from Rental Market 11. Government Order 12. Vacating an Unpermitted Rental Unit This ordinance would establish specific reasons for which a tenant can be evicted. It will allow for landlords to evict their tenants when there is a just reason and it will protect tenants from unjust evictions such as retaliatory evictions in response to requests for repairs to their unit and Code Enforcement inspections. Tenants who are displaced by landlord actions such as evictions are faced with unfair burdens. Landlords often require that prospective tenants pay the equivalent of three months' rent up front to secure a lease—generally representing the first and last month's rent, and a security deposit. for change ofhomes'affordable Orange low-income systemic resulting in the production to County's extremely households The total accumulated cost imposed on a displaced household generally exceeds $10,000 and can frequently reach $20,000 or greater. Tenants who are seniors, persons with disabilities, or have children incur even higher costs due to their particular circumstances. Low- and moderate -income tenants cannot afford such sudden and costly expenses, and they often experience homelessness as a direct consequence of eviction, which itself imposes further financial, social, health, and emotional costs. The severe financial impacts of displacement on tenants pose a threat to the public health, and safety, and welfare of the residents in the City of Santa Ana. There is an immediate need for tenant protections from unjust evictions. We strongly urge the City Council to support its tenants through the immediate adoption and implementation of a Just Cause Evictions Ordinance. Sincerely, s Cesar Covanubias Executive Director Working for systemic change resulting in the production of homes affordable to Qrange Coupty's extremely IoW -income households Orozco, Norma From: Isuri Ramos < Sent: Tuesday, December 04, 2018 3:11 PM To: Huizar, Maria; eComment Cc: Laura Kanter Subject: 85B: Just Cause Evictions Ordinance Attachments: LGBT Center of OC - Just Cause Evictions Ordinance.pdf Please see attached correspondence from the LGBT Center of OC and confirm receipt. Thank you. Isuri S. Ramos The Kennedy Commission Community Organizer The Kennedy Commission Increasing Orange County's Affordable Housing Opportunities The content of this email is confidential and intended for the recipient specified in this message only. It is strictly forbidden to share any part of this message with any third party, without a written consent of the sender. If you received this message by mistake, please reply to this message and follow with its deletion, so that we can ensure such a mistake does not occur in the future. The LGBT Center OC December 4th, 2018 Mayor Pulido and City Councilmembers City of Santa Ana 20 Civic Center Plaza P.O. Bo 1988,1x131 Santa Ana, CA 92701 RE: 8511: Support - Just Cause Evictions Ordinance empowering Igbt orange county 0 W m n N The LGBT Center OC's mission is to advocate on behalf of the Orange County lesbian, gay, bisexual, transgender, queer and questioning community and provide services that ensure its well-being and positive identity. One of the oldest LGBT Centers in the nation, the LGBT Center OC has been advocating for equality - and justice for LGBTQ people in Orange County since 1971. At the heart of our mission, the LGBT Center Oc- fights to end anti-LGBT bigotry and discrimination and works to ensure that all LGBTQ people in Orange County and beyond are able to freely express their true selves and embrace life without, fear of rejection, m discrimination or violence. The LGBT Center OC serves more than 11,000 individuals each year through our robust programs and services, conducted within the context of unconditional acceptance of sexual orientation, gender identity and expression, and cultural diversity. 4 N We seek to promote comprehensive solutions to the housing crisis including policies designed to keep tenants housed and further prevent homelessness. This includes protecting tenants from unjust evictions, from 2011- 2016 there were 2,201 evictions carried out by the Orange County Sheriffs Department. We know that the number of evictions is much higher as many evictions go unreported, and that a significant number of eviction- are carried out without just cause. The City has the ability to implement a Just Cause Evictions Ordinance and provide protections from unjust evictions to its most vulnerable tenants. This ordinance would only permit for tenants to be evicted for the following reasons: 1. Failure to Pay Rent 2. Breach of Lease 3, Nuisance 4. Illegal Purpose 5, Refusal to Execute New Lease 6. Failure to Give Access 7. Subtenant in Sole Possession 8. Owner Move -in 9. Necessary and Substantial Repairs Requiring Temporary Vacancy 10. Withdrawal of the Unit Permanently from Rental Market 11. Government Order 12. Vacating an Unpermitted Rental Unit �b mientero ..mpow.vrin9 Iqh� on n9a caunly or 0 This ordinance would establish specific reasons for which a tenant can be evicted. It will allow for landlords too evict their tenants when there is a just reason and it will protect tenants from unjust evictions such as retaliatory'- evictions in response to requests for repairs to their unit and Code Enforcement inspections. Tenants who are v displaced by landlord actions such as evictions are faced with unfair burdens. Landlords often require that _d prospective tenants pay the equivalent of three months' rent up front to secure a lease—generally representing M the first and last month's rent, and a security deposit. The total accumulated cost imposed on a displaced household generally exceeds $10,000 and can frequently reach $20,000 or greater. Tenants who are seniors, o persons with disabilities, or have children incur even higher costs due to their particular circumstances. Low - and moderate -income tenants cannot afford such sudden and costly expenses, and they often experience homelessness as a direct consequence of eviction, which itself imposes further financial, social, health, and emotional costs. The severe financial impacts of displacement on tenants pose a threat to the public health, and safety, and welfare of the residents in the City of Santa Ana. x There is an immediate need for tenant protections from unjust evictions. We strongly urge the City Council to support its tenants through the immediate adoption and implementation of a Just Cause Evictions m Ordinance. Sincerely, 4u�s GvAei Jw do_vv&, VGrv4ev' , �, enter, rn'ipory e.l n9 i96r or.n,. , Orozco, Norma From: Vecindario Lacy < Sent: Tuesday, December 04, 2018 3:40 PM To: eComment; Huizar, Maria Subject: 85B: Just Cause Evictions Ordinance Attachments: VeLA - Just Cause Evictions.pdf Hola, Mandamos esta carta de apoyo para el tema 85B respeto a desalojo con Causa Justa. Por favor confinne que se recibio. Gracias. December 4, 2018 Mayor Pulido and City Councilmembers City of Santa Ana 20 Civic Center Plaza P.O. Bo 1988, M31 Santa Ana,CA 92701 RE: 8513: Support - Just Cause Evictions Ordinance Vecindario Lacy en Acci6n (VeLA) is a group of residents from the Lacy neighborhood that have united to advocate for their community. The group includes: mothers, fathers, students, individuals with special abilities and community leaders that share the vision of improving the quality of life in their neighborhood and the city of Santa Ana. All with the purpose of creating more opportunities for families to succeed. VeLA has been advocating for a Just Cause Evictions Ordinance with this City Council since October of 2017. We seek to promote comprehensive solutions to the housing crisis including policies designed to keep tenants housed and further prevent homelessness. This includes protecting tenants from unjust evictions, from 2011- 2016 there were 2,201 evictions carried out by the Orange County Sheriffs Department. We know that the number of evictions is much higher as many evictions go unreported, and that a significant number of eviction are carried out withoutjust cause. The City has the ability to implement a Just Cause Evictions Ordinance and provide protections from unjust evictions to its most vulnerable tenants. This ordinance would only permit for tenants to be evicted for the following reasons: 1. Failure to Pay Rent 2. Breach of Lease 3. Nuisance 4. Illegal Purpose 5. Refusal to Execute New Lease 6. Failure to Give Access 7. Subtenant in Sole Possession 8. Owner Move -in 9. Necessary and Substantial Repairs Requiring Temporary Vacancy 10. Withdrawal of the Unit Permanently from Rental Market 11. Government Order 12. Vacating an Unpermitted Rental Unit This ordinance would establish specific reasons for which a tenant can be evicted. It will allow for landlords to evict their tenants when there is a just reason and it will protect tenants from unjust evictions such as retaliatory evictions in response to requests for repairs to their unit and Code Enforcement inspections. Tenants who are displaced by landlord actions such as evictions are faced with unfair burdens. Landlords often require that prospective tenants pay the equivalent of three months' rent up front to secure a lease—generally representing the first and last month's rent, and a security deposit. The total accumulated cost imposed on a displaced household generally exceeds $10,000 and can frequently reach $20,000 or greater. Tenants who are seniors, persons with disabilities, or have children incur even higher costs due to their particular circumstances. Low- and moderate -income tenants cannot afford such sudden and costly expenses, and they often experience homelessness as a direct consequence of eviction, which itself imposes further financial, social, health, and emotional costs. The severe financial impacts of displacement on tenants pose a threat to the public health, and safety, and welfare of the residents in the City of Santa Ana. There is an immediate need for tenant protections from unjust evictions. We strongly urge the City Council to support its tenants through the immediate adoption and implementation of a Just Cause Evictions Ordinance. Sincerely, Vecindario Lacy en Acci6n (VeLA) Orozco, Norma From: Huizar, Maria Sent: Tuesday, December 04, 2018 3:49 PM To: Garcia, Stephanie; Orozco, Norma; Mitre -Ramirez, Norma; Rojano, Michael Subject: Fwd: SABHC Letter of Support for item 85B -Just Cause Ordinance Attachments: SABHC JC Letter of Support-Signed.pdf; ATT00001.htm Sent to ecomment email but it bounced back. Please process accordingly Mike, can you check with IT to address the problem. Thank you. Begin forwarded message: From: "Alexis Teodoro (SABHC)" < Date: December 4, 2018 at 3:33:32 PM PST To: "Huizar, Maria" <MHuizar@santa-ana.ora> Subject: SABHC Letter of Support for item 85B -Just Cause Ordinance Dear Madam City Clerk Maria Huizar, Good afternoon. I hope this email finds you well Maria. The SABHC is submitting a letter of support for agenda item 85B for tonight's city council meeting. Are you able to make copies to submit to council? Thank you for your attention to this matter. Alexis Teodoro Campaigns Strategist Santa Ana Building Healthy Communities This message contains information which may be confidential and privileged. Unless you are the addressee (or authorized to receive for the addressee), you may not use, copy or disclose to anyone this message or any information contained in this message. If you have received this message in error, please advise the sender by reply e-mail to and delete the message. Thank you very much. Este mensaje contiene informaci6n que puede ser confidencial y privilegiada. A menos que usted sea el destinatario (o autorizado para recibir al destinatario), usted no puede utilizar, copiar o revelar a nadie este mensaje o cualquier informaci6n contenido en este mensaje. Si ha recibido este mensaje por error, Avise al remitente por correo electr6nico de respuesta a y elimine el mensaje. Muchasgracias. �, ANA �•. Building Heal Com iitunitif December 4th, 2018 Santa Ana Building Healthy Communities Mayor Pulido and City Councilmembers City of Santa Ana 20 Civic Center Plaza P.O. Bo 1988, M31 Santa Ana, CA 92701 RE: 8513: Support - Just Cause Evictions Ordinance Dear Mayor and City Council, Santa Ana Building Healthy Communities (SABHC) is committed to addressing health inequities and improving opportunities for a healthy, thriving Santa Ana. SABHC understands that health is directly shaped by the circumstances in which people are born, raised, live, and work. Improving these circumstances is a collective responsibility and one that must be led by those directly impacted. We seek to promote comprehensive solutions to the housing crisis including policies designed to keep tenants housed and further prevent homelessness. This includes protecting tenants from unjust evictions, from 2011- 2016 there were 2,201 evictions carried out by the Orange County Sheriffs Department. We know that the number of evictions is much higher as many evictions go unreported. The City has the ability to implement a Just Cause Evictions Ordinance and provide protections from unjust evictions to its most vulnerable tenants. This ordinance would only permit for tenants to be evicted for the following reasons: 1. Failure to Pay Rent 2. Breach of Lease 3. Nuisance 4. Illegal Purpose 5. Refusal to Execute New Lease 6. Failure to Give Access 7. Subtenant in Sole Possession 8. Owner Move -in 9. Necessary and Substantial Repairs Requiring Temporary Vacancy 10. Withdrawal of the Unit Permanently from Rental Market 11. Government Order 12. Vacating an Unpermitted Rental Unit This ordinance would establish specific reasons for which a tenant can be evicted. It will allow for landlords to evict their tenants when there is a just reason and it will protect tenants from unjust evictions such as retaliatory evictions in response to requests for repairs to their unit and Code Enforcement inspections. Tenants who are displaced by landlord actions such as evictions are faced with unfair burdens. Landlords often require that prospective tenants pay the equivalent of three months' rent up front to secure a lease—generally representing the first and last month's rent, and a security deposit. The total accumulated cost imposed on a displaced household generally exceeds $10,000 and can frequently reach $20,000 or greater. Tenants who are seniors, persons with disabilities, or have children incur even higher costs due to their particular circumstances. Low- and moderate -income tenants cannot afford such sudden and costly expenses, and they often experience homelessness as a direct consequence of eviction, which itself imposes further financial, social, health, and emotional costs. The severe financial impacts of displacement on tenants pose a threat to the public health, and safety, and welfare of the residents in the City of Santa Ana. There is an immediate need for tenant protections from unjust evictions. We strongly urge the City Council to support its tenants through the immediate adoption and implementation of a Just Cause Evictions Ordinance. Sincerely, Ana Urzua Sustainability Director Santa Ana Building Healthy Communities Orozco, Norma From: Luis Sarmiento< Sent: Tuesday, December 04, 2018 5:41 PM To: eComment; mhuizar@santa-ana.organd Subject: Item 85B Attachments: Centro - Just Cause Evictions Letter of Support 12-4-2018.pdf Hello, Please find attached a letter from the Centro Cultural de Mexico, in support of item 85B on today's City Council agenda. Thank you, Centro Cultural de Mexico N rrrresid EL CENTRO Qb CULTURAL •'^ DE MEXICO December 4th, 2018 Mayor Pulido and City Councilmembers City of Santa Ana 20 Civic Center Plaza P.O. Be 1988, M31 Santa Ana, CA 92701 RE: 8513: Support - Just Cause Evictions Ordinance El Centro Cultural de Mexico, a community based organization of 24 years in Santa Ana, writes to urge your support for the Just Cause Evictions Ordinance today. The Centro is an alternative space in Santa Ana where the community can find cultural, educational, and artistic activities that strengthen their identities, develop their talents and develop a sense of leadership in their community. Santa Ana is suffering from the compounded effects of rent -hikes, evictions, and real estate speculation that are pushing residents into overcrowded and inhumane housing conditions, or out of Santa Ana altogether. We seek to promote comprehensive solutions to the housing crisis including policies designed to keep tenants housed and further prevent homelessness. This includes protecting tenants from unjust evictions, from 2011- 2016 there were 2,201 evictions carried out by the Orange County Sheriffs Department. We know that the number of evictions is much higher as many evictions go unreported. The City has the ability to implement a Just Cause Evictions Ordinance and provide protections from unjust evictions to its most vulnerable tenants. This ordinance would only permit for tenants to be evicted for the following reasons: 1. Failure to Pay Rent 2. Breach of Lease 3. Nuisance 4. Illegal Purpose 5. Refusal to Execute New Lease 6. Failure to Give Access 7. Subtenant in Sole Possession 8. Owner Move -in 9. Necessary and Substantial Repairs Requiring Temporary Vacancy 10. Withdrawal of the Unit Permanently from Rental Market 11. Government Order 12. Vacating an Unpermitted Rental Unit This ordinance would establish specific reasons for which a tenant can be evicted. It will allow for landlords to evict their tenants when there is a just reason and it will protect tenants from unjust evictions such as retaliatory evictions in response to requests for repairs to their unit and Code Enforcement inspections. Tenants who are displaced by landlord actions such as evictions are faced with unfair burdens. Landlords often require that prospective tenants pay the equivalent of three months' rent up front to secure a lease—generally representing the first and last month's rent, and a security deposit. The total accumulated cost imposed on a displaced household generally exceeds $10,000 and can frequently reach $20,000 or greater. Tenants who are seniors, persons with disabilities, or have children incur even higher costs due to their particular circumstances. Low- and moderate -income tenants cannot afford such sudden and costly expenses, and they often experience homelessness as a direct consequence of eviction, which itself imposes further financial, social, health, and emotional costs. The severe financial impacts of displacement on tenants pose a threat to the public health, and safety, and welfare of the residents in the City of Santa Ana. There is an immediate need for tenant protections from unjust evictions. We strongly urge the City Council to support its tenants through the immediate adoption and implementation of a Just Cause Evictions Ordinance. "Cuando la cultura muere, la gente muere... Orozco, Norma From: Sandra Ortega < Sent: Tuesday, December 04, 2018 5:53 PM To: eComment; Huizar, Maria Subject: Just Cause Eviction Letter of Support Attachments: Just Cause.supportletter.pdf Good Afternoon, Please find the attached letter of support from Clergy and Laity United for Economic Justice for Just Cause Evictions. Feel free to contact me if you have any questions. Thank you Sandra Ortega Senior Faith -Rooted Organizer Clergy and Laity United for Economic Justice betty Hung, Esq. 1 1. Failure to Pay Rent 41ynndana Sheylin December 4th, 2018 CLUEMayor Disney Worker, UNITE -HERE Faith -Rooted Organizer Pulido and City Councilmembers Mary5tancavage City of Santa Ana Nuisance 20 Civic Center Plaza Clergy a Lofty United for Economic Justice p OBe1988 M31 P.O. > Board of Santa Ana, CA 92701 Directors All Tweini 'teamsters Local 2010 6. RE: 85B: Support - Just Cause Evictions Ordinance -Rev. Harman Copeland 7. Chair The Nall Las Memories Project So eat ante church CLUE brings together clergy and lay leaders of all faiths with workers, immigrants and Rabbi pr. AfVewes h Cohan American 7ewiStr University low-income families in the cause of a just economy that works for all and protects those J Y :Rev. Jim conn, 6av't most vulnerable. United Methodist Church (Rat.) Rabbi Dr. Stephen J. Einstein Congregation R'nal Tzedak We seek to promote comprehensive solutions to the housing crisis including policies (Emeritus), Fountain Valley designed to keep tenants housed and further prevent homelessness. This includes 'rhe Rev. Francisco Garcia Treasurer protecting tenants from unjust evictions, from 2011- 2016 there were 2,201 evictions P g j Ings Faithwood Episcopal Church, Inglewood carried out b the Orange Count Sheriffs Department. We know that the number of Y g Y P Father Mike Gutierrez evictions is much higher as many evictions go unreported. The City has the ability to 5t, IJaml the Dapr CatholicChurch, Raltlwin Fork implement a Just Cause Evictions Ordinance and provide protections from unjust Rev. Pr. Sarah Halvorson- evictions to its most vulnerable tenants. Cana Falrvievr Community Church, Carta Mesa This ordinance would only permit for tenants to be evicted for the following reasons: betty Hung, Esq. 1 1. Failure to Pay Rent 41ynndana Sheylin 2. Breach of Lease Disney Worker, UNITE -HERE Faith -Rooted Organizer Mary5tancavage 3. Nuisance Gishop Mary Ann Swenson 4. Illegal Purpose rUnited Methodist church (tart.,) 5. Refusal to Execute New Lease All Tweini 'teamsters Local 2010 6. Failure to Give Access Rlchard Zslalvar 7. Subtenant in Sole Possession The Nall Las Memories Project 8. Owner Move -in Staff 9. Necessary and Substantial Repairs Requiring Temporary Vacancy Jeremy Arnold 10. Withdrawal of the Unit Permanently from Rental Market Faith -Rooted Organizer Rev. Rebecca ttljur 11. Government Order Development rhyDirector Juan Carlos Durruthy 12. Vacating an Unpermitted Rental Unit Faitlrkuoted Organizer 9ue -anode ait ith�Rnoted Organizer Fa s ordinance would sP This establish specific reasons for which a tenant can be evicted. It will ,Rev. Rao Ghon Huang allow for landlords to evict their tenants when there is a just reason and it will protect :Falth-Rooted Organizer Pastor cue Jr, -Marie tenants from unjust evictions such as retaliatory evictions in response to requests for ralth-Rooted organizer repairs to their unit and Code Enforcement inspections. Tenants who are displaced by .Kevin Johnson Operations Manager landlord actions such as evictions are faced with unfair burdens. Landlords often require Sandra Ortega lth-RutY7=Ruatad Organiser Sr. F�41 that prospective tenants pay the equivalent of three months' rent up front to secure a Guillermo Torres lease—generally representing the first and last month's rent, and a security deposit. The Interim Dir. of organizing total accumulated cost imposed on a displaced household generally exceeds $10,000 and can frequently reach $20,000 or greater. Tenants who are seniors, persons with disabilities, or have children incur even higher costs due to their particular circumstances. Low- and moderate -income tenants cannot afford such sudden and costly expenses, and they often experience homelessness as a direct consequence of eviction, which itself imposes further financial, social, health, and emotional costs. The severe financial impacts of displacement on tenants pose a threat to the public health, and safety, and welfare of the residents in the City of Santa Ana. There is an immediate need for tenant protections from unjust evictions. We strongly urge the City Council to support its tenants through the immediate adoption and implementation of a Just Cause Evictions Ordinance. Sincerely, Senior Organizer Clergy and Laity United for Economic Justice PUBLICLAW CENTER _ P PROVIDING ACCESS TO JUSTICE FOR ORANGE COUNTY'S LOW INCOME RESIDENTS December 4, 2018 VIA PERSONAL DELIVERY Mayor Pulido and Members of the Santa Ana City Council City of Santa Ana 20 Civic Center Plaza P.O. Bo 1988, M31 Santa Ana, CA 92701 RE: 8513: Support - Just Cause Eviction Ordinance Dear Mayor Pulido and Honorable Members of the Santa Ana City Council: We write to submit a letter of support for the following item Santa Ana City Council Item 85B— Just Cause Eviction Ordinance. The Public Law Center is a non-profit pro bono law firm in Orange County that provides access to justice for low-income and vulnerable residents. In our Housing and Homelessness Prevention Unit, we represent low-income families in housing - related matters and advocate for sensible strategies to end homelessness in Orange County. We also collaborate with community organizations, statewide advocates, and law firms to push Orange County jurisdictions to create and maintain effective housing policies for lower-income working families. We seek to promote comprehensive solutions to the housing crisis including policies designed to keep tenants housed and further prevent homelessness. Our advocacy work includes helping tenants lmderstand their legal rights as renters, and providing legal representation in the eviction process, with the hopes of protecting them from unjust evictions. Upon information and belief, we understand that during the years of 2011- 2016, there were 2,201 evictions carried out by the Orange County Sheriffs Department. However, we know that the number of evictions is much higher, as many evictions go unreported, or tenants are evicted without any lawful notice or full understanding of their rights. The City of Santa Ana has the ability to aid its constituency and help prevent unlawful evictions, which can lead to displacement and homelessness by implementing a Just Cause Eviction Ordinance and providing protection from unjust evictions to its most vulnerable tenants. �_�p: Support- Just Cause Lvictions Urdinance December 4, 2018 0.2 . This ordinance would only permit for tenants to be evicted for the following reasons: 1. Failure to Pay Rent 2. Breach of Lease 3. Nuisance 4. Illegal Purpose 5. Refusal to Execute New Lease 6. Failure to Give Access 7. Subtenant in Sole Possession 8. Owner Move -in 9. Necessary and Substantial Repairs Requiring Temporary Vacancy 10. Withdrawal of the Unit Permanently from Rental Market 11. Government Order 12. Vacating an Unpermitted Rental Unit This ordinance would establish specific reasons for which a tenant can be evicted. It will allow for landlords to evict their tenants when there is a just reason and it will protect tenants from unjust evictions such as retaliatory evictions in response to requests for repairs to their unit and Code Enforcement inspections. Tenants who are displaced by landlord actions such as evictions are faced with unfair burdens, Landlords often require that prospective tenants pay the equivalent of three months' rent up front to secure a lease—generally representing the first and last month's rent, and a security deposit. The total accumulated cost imposed on a displaced household generally exceeds $10,000 and can frequently reach $20,000 or greater. Tenants who are seniors, persons with disabilities, or have children incur even higher costs due to their particular circumstances. Because Low- and moderate -income tenants cannot afford such sudden and costly expenses, they often experience homelessness as a direct consequence of eviction, which itself imposes further financial, social, health, and emotional costs. The severe financial impacts of displacement on tenants pose a threat to the public health, and safety, and welfare of the residents in the City of Santa Ana. There is an immediate need for tenant protections from unjust evictions. We strongly urge the City Council to support its tenants through the immediate adoption and implementation of a Just Cause Eviction Ordinance. Sincerely, /s/ Ugochi Anaebere-Nicholson Directing Attorney, Housing and Homelessness Prevention Unit