Munguia-Brown v. Equity Residential
- Jeffrey White
- 4:16-cv-01225
- U.S. District Court · Northern District of California
- 2
In Munguia-Brown v. Equity Residential, Judge White ordered further briefing on an injunction and final damages after finding California lease late-fee provision void.
The plaintiffs and Equity Residential, particularly regarding Equity’s Standard Late Fee provision, potential future lease terms, requested injunctive relief, and the amount to be included in final judgment.
What happened
In Munguia-Brown v. Equity Residential, the court had previously found that Equity Residential’s Standard Late Fee provision in its California residential lease was null and void.
The court said the parties needed to address the requested permanent injunction and calculate the final judgment amount before judgment could be entered. The requested injunction would restrict Equity’s charging, collection, and future use of the fee, while the damages calculation had to follow specified expert methods and exclude certain amounts.
Judge Jeffrey S. White ordered the plaintiffs to brief or stipulate to these issues, allowed Equity Residential to respond, and set a deadline for the plaintiffs’ reply. The order did not enter final judgment or decide the requested injunction’s final terms.
The detailed version
- Munguia-Brown v. Equity Residential · No. 4:16-cv-01225
- Jeffrey White
- Apr. 8, 2024
Background
The court stated that its earlier Findings of Fact and Conclusions of Law determined that the Standard Late Fee provision in Equity Residential’s California residential lease was null and void. Before entering final judgment, the court identified two issues requiring additional briefing or a stipulation by the parties.
Requested Injunction
The plaintiffs sought an injunction that would permanently prevent Equity from charging or collecting the Standard Late Fee, permanently prevent Equity from including that fee or any percentage-based late fee in future leases, and limit for three years after judgment the amount of any late fee Equity could charge to a reasonable amount based on the court’s findings about actual damages caused by late rent.
The court stated that the factors for issuing an injunction had not been fully briefed. Those factors included whether the plaintiffs suffered irreparable injury, whether money damages were inadequate, whether the balance of hardships supported equitable relief, and whether an injunction would serve the public interest. The court specifically noted that briefing was needed concerning the amount Equity could charge instead of $50 or 5 percent of outstanding rent.
Final Judgment Amount
The court also required the plaintiffs to provide the final judgment amount. That amount could not include the late-added $815,000 or prejudgment interest, and it had to be updated using post-trial numbers. The parties were instructed to use Mr. Breshears’ methods for calculating total late-fee charges and payments. Any offset for Equity’s damages was limited to a portion of its claimed employee costs, calculated using Mr. Schwarz’s multiple-regression analysis, and Equity’s lost-use-of-funds figures had to be calculated using Mr. Breshears’ methodology.
Order
The court ordered the plaintiffs to brief or stipulate to the issues by May 3, 2024. Equity could respond by May 24, 2024, and the plaintiffs’ reply was due June 7, 2024. The order required further submissions before final judgment; it did not itself enter final judgment or specify the final injunction terms.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.