Featured Chrome Extensions:

Casey IRACs are produced by an AI that analyzes the opinion’s content to construct its analysis. While we strive for accuracy, the output may not be flawless. For a complete and precise understanding, please refer to the linked opinions above.

Keywords

discriminationleasecivil rights
plaintiffappealtrialcivil rights

Related Cases

Great Atlantic & Pac. Tea Co. v. Supermarket Equipment Corp., 340 U.S. 147, 71 S.Ct. 127, 95 L.Ed. 162, 87 U.S.P.Q. 303
View Case »
Zeglin v. Gahagen, 571 Pa. 321, 812 A.2d 558
View Case »
Murphy v. California, 414 U.S. 833, 94 S.Ct. 173, 38 L.Ed.2d 68
View Case »
Jackson v. Smith, 254 U.S. 586, 41 S.Ct. 200, 65 L.Ed. 418
View Case »
United States v. Craft, 99 F.4th 407
View Case »
Justia Law Link
LexisNexis Link
Westlaw Link
CourtListener Link
Oyez Link

Marina Point, Ltd. v. Wolfson, 30 Cal.3d 721, 640 P.2d 115, 180 Cal.Rptr. 496, 30 A.L.R.4th 1161

Facts

Marina Point, a privately owned apartment complex in Marina del Rey, initially allowed families with children to rent apartments. In October 1974, the landlord changed its policy to exclude all families with children, despite having over 60 families with children already living there. The Wolfsons, who had a child, were informed their lease would not be renewed due to this policy. They contended that the exclusion violated their rights under the Unruh Act and other laws.

Plaintiff Marina Point, Ltd. (hereafter landlord or Marina Point) is a privately owned apartment complex, which, at the time of trial, consisted of 846 separate apartment units.

Issue

Whether a landlord can lawfully refuse to rent to families solely because they include a minor child, in violation of the Unruh Civil Rights Act.

The tenants now appeal from the judgment in favor of the landlord, contending that the exclusionary policy violates their statutory rights under the Unruh Civil Rights Act ( Civ.Code, § 51 et seq. ) and the California Fair Housing Law ( Health & Saf.Code, § 35700 et seq. , now Gov.Code, § 12955 ) and, in addition, impermissibly infringes upon their state and federal constitutional rights of familial privacy ( U.S.Const., 9th & 14th Amends., Cal.Const., art. I, § 1 ) and equal protection of the law.

Rule

The Unruh Act prohibits arbitrary discrimination by business establishments against any class of individuals, and its protections extend to all persons, not just specifically enumerated classes.

The Unruh Act prohibits business establishments from withholding their services or goods from a broad class of individuals in order to “cleanse” their operations from the alleged characteristics of the members of an excluded class.

Analysis

The court found that the municipal court erred in interpreting the Unruh Act as only protecting certain classes. It emphasized that the act's language and history indicate a broad prohibition against arbitrary discrimination, including against families with children. The landlord's justification for the exclusion based on children's behavior was deemed insufficient to uphold the policy.

As our prior decisions teach, the Unruh Act preserves the traditional broad authority of owners and proprietors of business establishments to adopt reasonable rules regulating the conduct of patrons or tenants; it imposes no inhibitions on an owner's right to exclude any individual who has committed no such misconduct cannot be excluded solely because he falls within a class of persons whom the owner believes is more likely to engage in misconduct than some other group.

Conclusion

The Supreme Court reversed the municipal court's judgment, ruling that the landlord's exclusionary policy violated the Unruh Act.

Accordingly, we conclude that the judgment in favor of the landlord should be reversed.

Who won?

The tenants (Wolfsons) prevailed because the court found the landlord's policy of excluding families with children to be discriminatory and in violation of the Unruh Act.

The Wolfsons now appeal from the judgment, asserting that both the Unruh Act and the Fair Housing Law bar the landlord's admitted policy of discriminating against families with children.

You must be