Barrientos v. 1801-1825 Morton LLC (2009)

Citation: Barrientos v. 1801-1825 Morton LLC (2009)
Parent Document: Barrientos v. 1801-1825 Morton LLC (2009)
Jurisdiction: United States (federal)
Effective Date: 2009-10-09
Original Source: https://www.courtlistener.com/opinion/3065171/barrientos-v-1801-1825-morton-llc/ ↗

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The City of Los Angeles adopted LARSO in 1979. It is a
comprehensive rent and eviction control ordinance, which
creates an exception to the general rule allowing “no-cause”
terminations at the end of a lease term. Its express purpose is
to “regulate rents so as to safeguard tenants from excessive
rent increases, while at the same time providing landlords
with just and reasonable returns from their rental units.” L.A.
Mun. Code § 151.01. Under LARSO, landlords and tenants
may set the initial terms of the tenancy, including the rental
rate, id. at § 151.06C, but thereafter, the landlord may only
increase the rent in small increments each year, absent special
permission, id. § 151.06D. Most importantly, LARSO
restricts possible grounds for eviction to thirteen enumerated
reasons, including violation of material terms of the lease,
damage to property, or criminal activity. Id. § 151.09A(1)-(7).
The only business-related reasons are renovation, removal of
the unit from the rental market, or placement of a family
member or resident manager into the unit. Id.
§ 151.09A(8)-(11). Expiration of the lease term or the desire
to raise rent to current market levels with a new tenant are not
permissible grounds for eviction. Through “vacancy decon-
trol,” however, when a tenant voluntarily leaves or is lawfully
evicted, the landlord may raise the rent to market levels. Id.
§ 151.06C. Though some public housing is exempt, LARSO
specifically applies to “rental units for which rental assistance
is paid pursuant to the Housing Choice Voucher Program cod-
ified at 24 CFR part 982.” L.A. Mun. Code § 151.02 Rental
Units (5). C.      Factual and Procedural Background

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