Los Angeles rent escrow program upheld under constitutional challenge

The Ninth Circuit upheld Los Angeles’s Rent Escrow Account Program that enables tenants to pay rent to a public account rather than to the landlord if the landlord fails to repair habitability violations. Sylvia Landfield Trust v. Los Angeles, 2013 WL 4779664 (9th Cir. 2013). The court found that the program served the legitimate government goal of ensuring compliance with regulations ensuring safe and habitable housing for tenants and that the program had adequate procedural safeguards to ensure it was not applied arbitrarily.