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DRAFT FOR ATTORNEY REVIEW — NOT FINAL

Boyd v. Carter (2014)

Citation
Boyd v. Carter (2014)
Parent Document
Boyd v. Carter (2014)
Jurisdiction
California (state)
Effective Date
2014-07-08

Full Text

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 1   applying a de novo standard of review. (See Ghirardo v. Antonioli (1994) 8 Cal.4th 791, 799;
 2   Nguyen v. Calhoun (2003) 105 Cal.App.4th 428, 437-438.)
 3          III.    Analysis
 4                  A.      The Carters Were Entitled to Assert and Litigate Affirmative Defenses
                            Concerning Habitability and Retaliatory Eviction in This Proceeding
 5
 6          The Carters posit that the trial court erroneously prohibited them from presenting their
 7   retaliatory eviction and habitability defenses, which are affirmative defenses permitted by
 8   statute and common law in an unlawful detainer proceeding. (Civ. Code §§ 1941, 1942.4 &
 9   1942.5; Code Civ. Proc. § 1174.2; Green v. Superior Court (1974) 10 Cal.3d 616, 635 (Green);
10   S.P. Growers Assn. v. Rodriguez (1976) 17 Cal.3d 719, 723 (S.P. Growers); Vargas v.
11   Municipal Court (McAnally Enterprises, Inc.) (1978) 22 Cal.3d 902, 916 (Vargas); Barela v.
12   Superior Court (Valdez) (1981) 30 Cal.3d 244, 249 (Barela).)
13          With respect to the habitability defense, Boyd retorts that, consistently with what the
14   trial court determined, the Carters‟ habitability defense was waived or forfeited because they did
15   not check the box on the first page of the Judicial Council answer form, which states, “Plaintiff
16   has breached the warranty to provide habitable premises.”
17          The Carters concede that they did not check this box on the answer form. But they
18   contend that they nonetheless asserted a habitability defense by the statements handwritten on
19   page two of their answer regarding claimed habitability problems. They contend that this, along
20   with the attachments to their answer, was sufficient, to put Boyd on notice that this affirmative
21   defense was in issue at trial. They further contend the same statements in their answer also
22   raised their defense that the eviction was retaliatory and in response to their deduction of rent in
23   December 2012 and their complaint about habitability conditions to the City of Sunnyvale.
24          The Carters‟ contention as to the sufficiency of pleading of both affirmative defenses
25   has merit. Their allegations that the residence “was not move-in ready,” that they had to make
26   repairs to make it “livable,” and that “the house was code tag[ged by] code enforcement to be
27   uninhabitable, and things needed to be repair[ed] by certain date” were sufficient, along with the
28   letters and other attachments to their answer, to put Boyd on notice that they were asserting an