Facts: An owner purchased a mobile home park in a location governed by a rent control ordinance. The ordinance limited the increase in monthly rent charged to new buyers to 75% of the change in the consumer price index (CPI).

Claim: The owner sought money damages, claiming the rent control ordinance was an unconstitutional taking of profit from the owner since the ordinance limited the ability of the owner to charge fair market rent for their mobile home lots.

Counterclaim: The city sought to enforce the rent control ordinance, claiming the owner purchased the property when the rent control ordinance was already in effect, and thus, no taking occurred as the owner did not experience an unforeseeable economic disadvantage.

Holding: A California court of appeals held the rent control ordinance was not an unconstitutional taking since the owner purchased the property when the rent control ordinance was already in effect and the owner did not experience unforeseeable economic disadvantage. [MHC Financing Limited Partnership v. City of San Rafael (9th Cir. 2013) 714 F3d 1118]