The Law Journal, Winter 2017 by CACM-California Association of Community Managers

IN THIS ISSUE REFEREEING DISCRIMINATION CLAIMS UNDER THE FAIR HOUSING ACT: What is an association supposed to do when it receives a discrimination or harassment complaint? Unfortunately, HUD’s advice to take “whatever actions the association legally can take to end the harassing conduct” is too vague to provide solid guidance on how to handle a specific situation. See page 1.

THE PRICE OF WAR: Strife on an association board can sometimes cause volunteers to leave board service never to return. In the worst of cases, directors will turn on each other and entrench for war, leading to unexpected consequences and costs! See page 5.

WINTER 2017

Refereeing Discrimination Claims Under the Fair Housing Act BY DAVID F. FEINGOLD, ESQ. AND MATTHEW HAULK, ESQ. – RAGGHIANTI FREITAS LLP

iscrimination and harassment complaints are some of the most difficult to resolve for a community manager. In 2016, the Department of Housing and Urban Development (commonly known as HUD) passed new regulations that make handling these complaints even more complex. Under the new

regulations, associations are not only responsible for their own conduct, but they are also responsible for “hostile environment harassment.” This means that an association must “referee” complaints regarding residenton-resident harassment and, when appropriate, take disciplinary action to ensure a

discrimination-free living environment. When an association receives this type of complaint, the first step should always be to consult with counsel. But what comes after that? We’ve developed a playbook for responding to these types of complaints, using the question: “DID you respond correctly by Documenting,

Investigating and Disciplining?”

The Legal Playing Field Under the new regulations, an association must take action when it knows (or should know) that there is “hostile environment harassment” in the community based on race, disability or any other protected characteristic. The term Continued on page 2

THE

Law Journal

A Practical Review of Community Management Law Published by

California Association of Community Managers, Inc. 23461 South Pointe Dr., Ste. 200 • Laguna Hills, CA 92653 949.916.2226 • 800.363.9771 Fax: 949.916.5557 • www.cacm.org

2017-2018 CACM LEGAL ADVISORY STEERING COMMITTEE CHAIR Susan Janowicz, CAMEx, CCAM-LS East Lake Village Community Assn.

EDITORS David Zepponi President & CEO, CACM Frederick T. Whitney, Esq. Neuland, Whitney & Michael, APC

GUEST EDITORS Kelly Moss, CCAM-PM Eugene Burger Management Corporation Melissa Ward, Esq. Hughes Gill Cochrane, PC

COMMITTEE MEMBERS Frank Alioto III, CCAM Community Management Services, Inc. Jeffrey Beaumont, Esq. Beaumont Gitlin Tashjian

Refereeing Discrimination Claims Continued from page 1

“hostile environment harassment” means (among other things) that there is unwelcome conduct that is so severe or pervasive that it interferes with a person’s ability to use or enjoy their unit and the common areas at the association. There are no hard and fast rules as to when a hostile environment exists. Courts instead look to the “totality of the circumstances,” which is a case-by-case determination based on the particular facts of the situation. For example, if a resident with an emotional support dog is repeatedly harassed by another resident for bringing her dog into common areas, or if one resident yells racial slurs at another resident during an argument, there may be a hostile living environment and the association must respond.

A Playbook for Responding to Complaints What is an association supposed to do when it receives a complaint? Unlike an employer or landlord, an association can’t simply fire or evict the homeowner who is behaving badly. HUD’s advice is for the association to take “whatever actions it legally can take to end the harassing conduct,” including “imposing conditions authorized by the association’s CC&Rs or by other legal authority.” This advice is too vague to provide solid guidance on how to handle a specific situation.

Gene Bicksler, CCAM Bicksler & Associates Chris Bonkowski. Iger Wankel & Bonkowski, LLP Cecilia Brennan, Esq. The Perry Law Firm Corinne Crawford, CAMEx, CCAM-ND The Management Trust - Southern California, ACMB Roger Grant, Esq. Fenton Grant Mayfield Kaneda & Litt, LLP Betina Hunt, CCAM Homeowners Management Company, LLC Zer Iyer, Esq. Angius & Terry LLP Tina Jackson-Walda, CCAM Alliance HOA Management, LLC Jennifer Jacobsen, Esq. Baydaline & Jacobsen LLP Karen Martinez, CAMEx, CCAM ASPM-San Diego Brian Moreno, Esq. SwedelsonGottlieb W. Alexander Noland, Esq. Noland Law PC Andrea O'Toole, Esq. Berding | Weil LLP Joseph Price, CAMEx, CCAM RealManage Darren Shaw, CAMEx, MCAM-LS.AA DC Ranch Association Margaret (Gen) Wangler, Esq. Fiore Racobs & Powers, APLC The CACM Law Journal is distributed four times annually to members, affiliates and supporters of the California Association of Community Managers. DISCLAIMER: CACM does not assume responsibility for the accuracy of articles, events or announcements listed. Please be advised that the opinions of the authors who contribute to the Law Journal are those of the author only, and do not necessarily reflect the opinions of CACM and other industry attorneys. Please note that in a constantly evolving industry there are frequently multiple interpretations of the controlling statutes and case law. If you have any questions, please discuss them with your association’s legal counsel.

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Unlike an employer or landlord, an association can’t simply fire or evict the homeowner who is behaving badly.

We propose a three-step playbook: Document the complaint, Investigate the facts, and Discipline as appropriate. Document: • Create and maintain a written record of the complaint and the association’s response • Encourage (but not require) residents who call-in complaints to provide written statements • Respond to every complaint in writing

Investigate: • Investigate every complaint (even minor or inconsequential ones) • Contact witnesses who may have observed the harassment • Notice and conduct a hearing with the alleged harasser to get their side of the story • Consult with counsel to consider the evidence and evaluate the association’s legal options

Discipline: • Inform appropriate authorities as necessary • Send the problem homeowner a cease and desist letter • After a hearing, discipline harasser as authorized by the governing documents • If the harassment continues, the association should consider submitting a complaint directly to HUD Associations should also consider adopting “antiharassment” policies to advise homeowners and residents of their right to a discrimination-free housing environment and to provide the contact information for the state and federal agencies that can provide further assistance. If you want to learn more, check out the new regulations and HUD’s commentary on how they may apply to your community by searching the new regulations (“24 CFR 100, section 100.600” and “84 CFR 63054”) or visiting www.hud.gov.

ABOUT THE AUTHORS David F. Feingold, Esq. and Matthew Haulk, Esq. are with the law firm Ragghianti Freitas LLP in San Rafael. They have practiced Common Interest Development law and litigation for 26 years and five years, respectively.

Solar Rights Act & DSA Laws An Imperfect Balance of Encouraging Rooftop Solar Energy Systems and Preserving Property Rights BY CHRISTINA BAINE DEJARDIN, ESQ. – PETERS & FREEDMAN, L.L.P.

n October 15, 2017, Governor Jerry Brown signed into law Assembly Bill No. 634, which not only modifies Civil Code § 714.1 of the Solar Rights Act but also amends Civil Code § 4600 and adds Civil Code § 4746 to the Davis-Stirling Common Interest Development Act. The new laws will take effect on January 1, 2018. This bill seeks to make installation of rooftop solar energy systems easier and cheaper for condominium owners. However, like the electric vehicle charging station bill before it, the bill fails to take into account the joint ownership character of common area roofs and therefore arguably undercuts both an association’s right to operate, control and manage the common area and other owners’ property rights. The bill requires the following: • Authorizes the installation or use of solar energy systems that are intended for household purposes on the roof of the building in which the owner resides or on the garage or carport adjacent to the building that has been assigned to the owner for exclusive use. • Carves out a new exemption for the Civil Code § 4600 member approval requirement for grants of exclusive use common area solar energy systems on common area roofs. • Enacts new Civil Code § 4746, which establishes certain notification requirements and imposes insurance requirements on installing owners. • Civil Code § 4746 allows additional, reasonable restrictions based on a solar site survey. The cost of the survey and determination of usable space are not deemed part of the “cost of the system” and thus are not subject to the limitations set forth in Civil Code § 714. Some permissible restrictions and association powers remain: • Owners and successive owners of the solar energy system are responsible for any costs for damage to the Common Area, Exclusive Use Common Area or separate interests resulting from the installation, maintenance, repair, removal or replacement of the system. Continued on page 4 www.cacm.org | The Law Journal 3

Discriminatory Leasing Practices Continued from page 3

It is that time of year again – when we look to the legislature for the new laws that affect the community association industry and when we look back on recent cases that will impact our association clients. Coming in right under the wire, a brand-new law regarding rooftop solar energy projects was signed by the Governor in October. Christina Baine DeJardin, Esq. provides a summary of the new legislation and suggests some ways to manage the questions and challenges that the legislation creates. Dispute resolution is always a major legal topic for associations, and Fred Whitney, Esq. and Constance Trinh, Esq. discuss the recent Lee v. Silveira case from the defense perspective. As they note, the “price of war” in HOA disputes can be unexpectedly high and result in long-term damage to everyone involved. Gen Wangler, Esq. provides her unique insight into the issue of document production (hint: it’s not as easy as you might think) and the case of Tract No. 72016 Association v. Parker. David Feingold, Esq. and Matt Haulk, Esq. provide some muchneeded clarity and a useful “playbook” for handling hostile environment and harassment claims brought pursuant to the FHA regulations. Finally, Mandy Hexom, Esq. provides some essential information and tips for handling collections in her article on the recent Mashiri v. Epsten case. I extend my sincere thanks to the authors for sharing their time and expertise and to my co-guest editor, manager Kelly Moss, who provided valuable input on topic ideas and article content. Thank you also to Law Journal editor Fred Whitney and especially to Randall Oliver, CACM Communications Manager, who stepped in at the last minute to take over production and administration of this issue, a process which was almost certainly akin to herding cats. I hope you enjoy the issue! Melissa B. Ward, Esq. is a principal with Hughes Gill Cochrane Tinetti, P.C. in Walnut Creek, CA. She has been serving as general counsel to common interest developments throughout Northern California since 2010 and has been a business and real estate attorney for over 25 years.

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• Owners are responsible for any costs for the maintenance, repair and replacement of the solar energy system until it is removed, and for the restoration of the Common Area, Exclusive Use Common Area, or separate interest that are necessitated after removal. • Owners are required to disclose to prospective buyers the existence of any system and the owner’s related responsibilities. The new law may have created more questions than it answered. Maintenance, repair and replacement obligations seem murky. What happens to the association’s roof warranty if part of the shared roof is penetrated as a result of the solar energy system? How does the association determine who gets to use the roof when there isn’t room for all to have a system? Is it “first-come, firstserved?” Additionally, while Civil Code § 4746 requires the applicant obtain a solar site survey to determine an equitable allocation of the useable solar roof area among all owners who share the roof, garage or carport, it does not tell the association what it should then do with that information. What if it receives conflicting site surveys? Should the association pay for its own “definitive” site survey?

Condominium associations will need to navigate this new legal and logistical quagmire that Sacramento has created. Determination of useable solar roof area may require an independent solar site survey commissioned by the association. Associations should work with their legal counsel to craft new rules and regulations that implement the mandatory and optional requirements set forth in the statute as well as the approach or policy it will take in relation to the allocating usable solar roof area, maintenance, repair and replacement of the affected roof area and roof warranty issues. Most owners and board members would agree that sustainable energy sources are commendable and should be supported in common interest developments. However, this interest must be balanced against the condominium association’s obligation to ensure that common area is protected and preserved for the use and enjoyment of all owners. Until we have case law or other legal guidance, we will have to work within the parameters of the new law by adopting or modifying solar energy system installation guidelines.

ABOUT THE AUTHORS Christina Baine DeJardin, Esq. works out of the Palm Desert office of the Peters & Freedman, LLP law firm. She has been practicing homeowners association law for the last 12 years.

Lee v. Silveira: The High Price of War BY FREDERICK T. WHITNEY, ESQ. & CONSTANCE TRINH, ESQ. OF NEULAND, WHITNEY & MICHAEL, APC

enerally speaking, board service tends to draw like-minded people eager to serve with little conflict involved. In some communities, however, conflict can develop over things as simple as pool renovations or paint schemes. Unfortunately, strife can sometimes cause volunteers to leave board service never to return. In the worst of cases, directors will turn on each other and entrench for war! The recent published case of Lee v. Silveira tells such an unfortunate tale. The Lee vs. Silveira battlefield was an ordinary condominium complex in San Diego known as Friars Village. Due to the economic challenges of the prior decade, maintenance within Friars Village fell into decline. In more recent years, the

economy recovered and several people ascended to board positions looking to resolve deferred maintenance issues and to improve the community. As repairs and improvements proceeded, three members of the association’s nine-member board (hereinafter the “Old Guard”) took umbrage with the decisions of the new board members (hereinafter the “Upstarts”), and, after finding themselves on the losing end of several board motions, took action to put a stop to it. Specifically, the Old Guard retained counsel and personally sued the six Upstarts for voting to re-roof; to upgrade common area; and to retain the current manager. For good measure, the Old Guard also sued the management company, the

managers that personally worked on the account, and two Upstarts who hadn’t even participated in some of the challenged votes. For some reason, the Old Guard opted not to pursue their claims against the association directly. What the Old Guard had failed to recognize, however, is that key elements of participation on a board of directors are constitutionally protected. Most notably, voting one’s conscience is an exercise of free speech that the law protects. When a director is sued personally based upon conduct that is protected (e.g. voting, non-defamatory comments at a board meeting, etc.), she or he can file a special motion called an “antiSLAPP” motion to have the claim thrown out on the grounds that it is an unlawful attempt to bully, intimidate

and silence a director. If the court agrees that the conduct alleged is constitutionally protected activity, then the plaintiffs have to prove to the court a substantial likelihood that they are going to win the entire case, or they are not allowed to proceed any further. If the plaintiffs fail in this burden, their claims are stricken and they lose their case. In response to the claims brought by the Old Guard, counsel for the Upstarts filed an anti-SLAPP motion arguing that the act of voting was constitutionally protected activity. Although brilliantly argued (in the humble opinion of the authors), the trial judge did not agree and denied the motion. In response, the Upstarts appealed. On appeal, the Fourth District reversed Continued on page 8

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Document Production is Not as Easy as You Might Think BY MARGARET G. WANGLER, ESQ. - FIORE, RACOBS & POWERS, A PLC

ssociation member Don Parker requested inspection of the membership list and other books and records of the Tract No. 7260 Association. The association refused, finding that Parker sought inspection for an improper purpose. Parker filed a lawsuit seeking a court order to compel inspection of the membership list and the other books and records requested. The trial court agreed with the association that Parker's requested inspection was for an improper purpose, and denied Parker's petition as to the books and records. However, the trial court granted the petition as to the membership list. In granting access to the membership list, the trial court relied on Corporations Code § 8330(b)(2). That statute provides that when a demand for the membership list is made by the "authorized number" of members, meaning at least five percent of the members, and the corporation believes that the request is not for a legitimate purpose, the corporation, not the requesting members, must file an action in court for an order setting aside the demand. The association did not file an action, leading to the trial court’s decision that the association could not withhold the list, even though the request was not for a proper purpose. On review, the California Court of Appeal upheld the

trial court's finding that Parker had sought the association records for an improper purpose. The Court first noted that a member's right of inspection of the corporation's membership list and other records is limited to purposes reasonably related to the member's interest as a member. The Court noted that

request was for an improper purpose. The Court then reversed the trial court's conclusion that the association could not withhold the membership list. The Court found that the request for the membership list was not made by the “authorized number” of members. Parker alone

list if it “reasonably believes” that the list will be used for an improper purpose. Only if the list is requested by the “authorized number” of directors, that is, 5 percent of the members, must the association seek a court order setting aside the request. The other take away is that if the association denies access to

Boards of directors must act cautiously when determining that a request for the membership list is for an improper purpose and be able to provide evidence to support its decision. Parker's stated purposes for the inspection were legitimate. Parker stated that he wanted to inspect the books to make certain the association was following generally accepted accounting principles, and wanted the membership list for possible communications with the members to ascertain whether there had been corporate misdeeds. But the association provided evidence that Parker’s real reason for the requested inspection was related to his involvement in a lawsuit between the association and the entity called “Fix the City,” with which Parker was associated. In fact, Parker submitted his inspection requests on the same day the association’s complaint against Fix the City was filed. The Court of Appeal found that the association met its burden of proving that the

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requested the list under Corporations Code § 8330(b) (1), which states that the membership list may be requested by: “Any member, for a purpose reasonably related to such person’s interest as a member. Where the corporation reasonably believes that the information will be used for another purpose, it may deny access to the list.” (Italics added.) Under this section of Corporations Code § 8330(b), the association was not required to initiate a court action; it could simply deny access to the list based on its reasonable belief that the information would be used for another purpose. One take away from Tract No. 7260 Association is that if the membership list is requested by one member, the association may withhold the

the list based on its belief that the list will be used for an improper purpose, the association has the burden of proof in the event of a court challenge to its decision. So boards of directors must act cautiously when determining that a request for the membership list is for an improper purpose and be able to provide evidence to support its decision.

ABOUT THE AUTHOR Margaret (Gen) Wangler, Esq. is an attorney with the law firm Fiore, Racobs & Powers, APLC in Palm Desert. She has been representing community associations for the past 29 years.

Association Debt Collectors Should Proceed Cautiously Lessons from Mashiri v. Epsten Grinnell & Howell BY MANDY D. HEXON, ESQ. – EPSTEN GRINELL & HOWELL, APC

n January 13, 2017, the Ninth Circuit Court of Appeal in Mashiri v. Epsten Grinnell & Howell, et al., 845 F.3d 984, addressed the issue of whether an association’s debt collector’s pre-lien letter to an assessment debtor (homeowner) violated the federal Fair Debt Collection Practices Act (“FDCPA”) based on how two required notices (discussed below) were provided in that letter. The two notices in the pre-lien letter at issue are required when collecting assessment debts and prior to an association recording an assessment lien. The first notice, known as the “Validation Notice,” is required by the FDCPA, 15 U.S.C. § 1692g, to be in the initial letter or communication from

a debt collector, which notifies the debtor of his or her right to dispute the debt within 30 days of receipt of the letter. The second notice, known as the “Pre-Lien Notice,” is required by Civil Code § 5660 of the Davis-Stirling Common Interest Development Act, requiring a 30 day notice of an assessment debtor’s rights before recording an assessment lien on the owner’s property. The issue in the Mashiri case was whether the Pre-lien Notice in the letter from the law firm conflicted with or overshadowed the Validation Notice under federal law. The lower district court ruled in favor of the law firm resulting in the debtor, Zakia Mashiri, filing the appeal to the Ninth Circuit. The Ninth Circuit reversed and, in its decision, provided some

guidance on how to provide the two notices in correspondence to debtors. It is up to association debt collectors to develop their own correspondence to debtors requiring the Validation Notice and Pre-Lien Notice to debtors. More often than not, prior to the Mashiri case, association debt collectors provided the two notices in one letter to the debtor. There has been little consistency in the industry in terms of form and procedure. Furthermore, the FDCPA and the Davis Stirling Act do not explain how to reconcile or explain the two notices. Therefore, prior to the Mashiri case, managers and law firms may have believed that as long as the two notices are provided in the letter or if additional time was added to the

minimum 30-day Pre-lien Notice, there was no running afoul of the FDCPA. Not so, says the Ninth Circuit in Mashiri. In this case, the Ninth Circuit stated that debt collectors are “obligated to explain such debt validation rights in an effective matter” and found the two deadlines in the letter at issue confusing, conflicted with or overshadowed the 30 day Validation Notice in violation of §§ 1692g and 1692e(5) of the FDCPA, despite the fact that additional time was added to the Pre-Lien Notice period. The Ninth Circuit did not say how to provide the two notices, only that debt collectors should “explain” the two notices to prevent any overshadowing or conflicts with the Validation Notice. Without further guidance on how to explain the two notices in one letter or whether it is sufficient to send two separate letters while the 30-day Validation Notice is pending, the answer is not clear. In my opinion, the safest practice is to first send the Validation Notice letter and then send the Pre-Lien Notice letter only after the 30-day Validation Notice period has expired and, if the debtor requests validation or disputes the debt, only after the debt has been properly validated Continued on page 8

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Lee vs. Silviera: The High Price of War Continued from page 3

Association Debt Collectors Proceed Cautiously Continued from page 7

the lower court’s denial, recognizing that California’s anti-SLAPP law protects an individual board member’s right to vote. Another fun fact about anti-SLAPP motions is that, if successful, the prevailing party is entitled to an award of attorney’s fees and costs. Thus, after all the dust settled, the trial court awarded just over $69,000 in attorney’s fees and costs against the Old Guard, which they will owe personally. In all, Lee vs. Silveira took close to three years of battle to complete. Most of the parties involved abandoned service on the board never to return. Several defendants sold their homes and left the community. Tensions between neighbors born of this conflict remain to this day, and the Old Guard faces tens of thousands of dollars in personal debt to fund the effort. Thus, the lesson for directors in Lee vs. Silveira is that war often takes on a life of its own after the first shot is fired and its price is often far greater than one might expect or be willing to pay.

for the debtor. Although sending two non-simultaneous letters will result in further delays before the association can record an assessment lien, it is better than running afoul of the FDCPA, its related state counterpart, the California Rosenthal Fair Debt Collection Practices Act, and possibly the California Unfair Business Practices Act. Although the debt collector in the Mashiri case was a law firm collecting association assessments, the ruling in the Mashiri case applies equally to all debt collectors including association managers that serve as “debt collectors” as defined under the law. Management companies should consult with an expert in this area of the law to determine whether their collection activities fall within the definition of “debt collectors” under federal or state law.

ABOUT THE AUTHOR

ABOUT THE AUTHOR Frederick T. Whitney, Esq. is a partner with the law firm Neuland & Whitney, APC in Rancho Santa Margarita. He has 18 years of experience practicing community association law. Constance Trinh, Esq., an associate attorney with Neuland & Whitney, has a decade of experience in real estate litigation and civil appeals, and served as trial and appellate counsel for the prevailing defendants in Lee v. Silveira.

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Mandy D. Hexom, Esq. has practiced general civil litigation since 2001. She is a senior attorney at law with Epsten Grinell & Howell, APC, which maintains offices in San Diego and Coachella Valley.

2017-2018

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