Williams v. Alameda County Board of Supervisors

Background

This order addresses two related cases. In Williams v. Alameda County, the plaintiffs challenge Alameda County and Oakland ordinances that prohibited evictions of non-paying tenants during the COVID-19 pandemic. Their claims include takings under the Fifth Amendment, inverse condemnation under the California Constitution, and due-process and equal-protection claims under the Fourteenth Amendment. In the related case, California Apartment Association v. Alameda County, the plaintiffs assert similar claims and also challenge the ordinance under the Contracts Clause and a California constitutional preemption theory concerning Ellis Act evictions.

The court had previously set an expedited schedule for the facial claims, denied summary judgment, and denied the plaintiffs’ request for an immediate appeal of the summary-judgment order. The cases had otherwise been stayed. The defendants moved to extend that stay while the Ninth Circuit considered three other COVID-19 eviction-moratorium cases: Jevons v. Inslee, Iten v. County of Los Angeles, and El Papel, LLC v. City of Seattle.

Legal standard

Under the Supreme Court’s decision in Landis, a federal court may stay proceedings to manage its docket efficiently. The court must balance the possible harm to the nonmoving party, the hardship to the party opposing the stay, and whether a stay would simplify or complicate the issues, evidence, and legal questions. If there is even a fair possibility that a stay would harm the nonmoving party, the party seeking the stay must show a clear case of hardship or unfairness from proceeding.

Court’s analysis

The court found a fair possibility of harm to the plaintiffs. John Williams declared that his renter owed $60,000 in back rent under the ongoing moratoria and that he had obtained mortgage forbearance, borrowed money from family members, and applied for food stamps to avoid losing his property to foreclosure. The defendants argued that damages could be addressed later, that the County’s moratorium would end on April 29, 2023, and that the plaintiffs’ earlier requests for stays showed a lack of harm. The court rejected those points because the City’s moratorium remained in effect, and the plaintiffs’ earlier requests had been strategic decisions that did not eliminate the potential harm from further delay.

The court also found that a stay would likely be inefficient. The appeals concerned only some of the claims in these cases, and discovery had not yet begun but would likely overlap across the claims. The court concluded that delaying discovery would probably create inefficiency rather than prevent wasted effort.

Disposition

The court denied the defendants’ motions to stay in both related cases and lifted the existing stay. The order resolved ECF No. 115 in No. 3:22-cv-01274-LB and ECF No. 57 in No. 3:22-cv-02705-LB. Judge Laurel Beeler signed the order as a United States Magistrate Judge.