Sage v. County of Monterey

Summary

The United States District Court for the Northern District of California granted Monterey County’s Rule 12(c) motion for judgment on the pleadings regarding Shasha Sage’s wrongful-eviction claim. The court held that Sage had not adequately alleged a leasehold or other property interest in the safe-parking space, and that her recreational vehicle was not real property for purposes of the asserted California common-law and statutory theories. The order was dated March 21, 2025.

Holdings

1. Sage could not base a common-law wrongful-eviction claim on eviction from her RV because the RV was not real property. Her allegations that she parked in the same space for two and a half years and performed upkeep services did not establish a leasehold interest because they did not allege that the services were bargained for in exchange for a property interest.
2. Sage failed to state a claim under California Civil Code section 1946 because she did not allege facts showing that she hired the parking space or paid, or bargained for the space in exchange for services.
3. Sage failed to state a claim under California Code of Civil Procedure section 1159 because she did not allege that she was a hirer or otherwise had a property interest in the parking space, and her RV was not real property for purposes of the statute.

Questions Presented

1. Whether Sage adequately pleaded a California common-law wrongful-eviction claim based on alleged possession of her RV or the parking space.
2. Whether Sage was a 'hirer' of real property entitled to the thirty-day notice protection of California Civil Code section 1946.
3. Whether Sage adequately pleaded a claim under California Code of Civil Procedure section 1159 by alleging possession of real property and forcible entry or forcible ouster.

Disposition

other