John F. Baumgardner, Esq. Chapman & Intrieri, LLP.
Winter 2025 Law Journal Committee Members
Mark Guithues, Esq. Community Legal Advisors
Rhonda Goldblatt Esq. Epsten APC
Lorena Sterling, CAFM Community Association Financial Services (CAFS)
Brenda Hendricks, CCAM The Helsing Group Inc., ACMC
Shanne Ho, CCAM-HR.ND ProActive Professional Management
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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. The information contained in these articles is of a general nature and not intended as legal advice. If you have any questions, please discuss them with your association’s legal counsel.
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Guest Editor’s Note
The passage of AB130 created a sudden and drastic change to the disciplinary process used by many community associations throughout California. Following its passage, the common interest development industry has voiced significant concerns regarding the $100 limitation for fines, the lack of guidance regarding “adverse health and safety” violations, the potential for litigation related to written findings at open board meetings and the threat posed by continuing violations of governing documents. Instead of protecting members from unreasonable fines, AB130 created the potential for increased general counsel fees and litigation to enforce a community association’s governing documents. These concerns were compounded by the fact that these significant changes were added to AB130 days before it was passed by the Legislature and that the requirements became effective almost immediately upon Governor Newsom’s signature.
AB130 reshaped the rules overnight. Now, community associations must rethink their entire disciplinary process.
Despite these valid concerns, it appears that the changes introduced by AB130 are here to stay for the foreseeable future. Although industry organizations will continue to fight for changes to this law, community associations and managers must be aware of revisions that need to be made to disciplinary processes and the remaining enforcement options. And, as discussed in depth in this issue, there are still options to enforce governing documents. While the industry awaits additional guidance from the courts or legislature, boards, with the assistance of their general counsel, will need to analyze the level of risk they are willing to incur in their disciplinary process.
While it may feel that the sky is falling, community associations will successfully navigate these changes just as they did after the passage of the balcony inspection bill, accessory dwelling construction requirements and changes to election rules. This industry is resilient, and this issue provides some tools to assist in its ongoing evolution.
John F. Baumgardner, Esq. Is the primary attorney with Chapman & Intrieri, LLP in their Roseville, California office. With 11 years of experience, his practice focuses on representing Homeowners Associations in complex construction defect disputes, general counsel matters, general civil litigation and revision of governing documents.
By William Curry, Esq. and Warren Katz, Esq.
UNDERSTANDING THE IMPACT OF AB 130
Effective July 1, 2025, Assembly Bill 130 (AB 130) amended the California Civil Code to impose restrictions on how homeowners’ associations (HOAs) can levy fines. The California Civil Code now limits monetary fines to $100 per “violation” with a few narrow exceptions. This seemingly straightforward cap has sparked substantial confusion throughout the industry.
ONE VIOLATION, ONE FINE?
One prominent interpretation of the new law - associations may levy only one $100 fine per instance of rule-breaking. After the single $100 fine, an association’s only options are ADR/litigation. This interpretation does not mesh with the concept of continuing violations.
CATEGORIES OF VIOLATIONS: ONE-TIME, RECURRENT, AND CONTINUING
To better grasp the implications of AB 130, it’s useful to categorize violations into three types: one-time, recurrent and continuing.
One-Time Violations
These are isolated incidents, such as a single instance of blocking a fire lane.
Recurrent Violations
These involve repeated but distinct actions (i.e., frequent trash violations or habitual parking violations). Industry consensus is forming that each recurrence constitutes a separate “violation” under AB 130, making a $100 fine for each occurrence allowable.
Continuing Violations
These involve an ongoing “violation” of the governing documents (i.e., maintaining unapproved construction or continued failure to maintain vegetation on a lot). Modernly, many governing documents include the maintaining of an unapproved improvement to be a violation of the CC&Rs. The act of the unapproved painting is a one-time violation, while maintaining the unapproved painting may constitute a continuing violation.
A continuing violation is drawn from the legal concept of a continuing nuisance. Generally, a set of CC&Rs will state that a violation of the CC&Rs constitutes a nuisance. California case law supports the concept of a continuing nuisance as a cause of action. Cutujian V Benedict Hills Estates Assn. 41 Cal. App. 4th 1379 states that “As a practical matter, this cause of action is identical to a cause of action for breach of an affirmative covenant running with the land, brought under the theory that breach of such covenant is a continuous breach giving rise to a new cause of action from day to day as long as the covenant is not performed.” (Id. at 1390).
Additionally, both Cutujian and Capogeannis v. Superior Court, 12 Cal. App. 4th 668 (Cal. App. 6th Dist. 1993) support the concept that if there is a continuing nuisance that “every repetition of [the] continuing nuisance is a separate wrong,” subject to a new and separate limitation period, “for which the person injured may bring successive actions for damages until the nuisance is abated, even though an action based on the original wrong may be barred” (Phillips v. City of Pasadena (1945).”(Id. at 676)
Under this model, each day of non-compliance (i.e., each day the continuing violation persists) may justify a new $100 fine, even if a fine was previously levied for that issue. Association boards must weigh the risks/liability to determine their association’s level of enforcement. A more conservative approach to enforcement of a continuing violation may be, after notice and a hearing, issuing a single fine once. A more aggressive board may decide that an owner will be subject to a combined value of weekly or daily fines. If an association is going to pursue a combined value of weekly or daily fines, the violation notice should include the days/times where the continuing violation was observed. While this interpretation may face legal challenges, it is arguably consistent with both common law and nuisance principles. Regardless, associations should meet with their general counsel to discuss changes in their fine schedules and enforcement policies.
Even with the above interpretation and basis for a continuing violation, AB 130 will inevitably
result in an increase in ADR/litigation. By utilizing this interpretation of “violation” and pursuing alternative enforcement remedies, such as selfhelp and suspension of privileges, an association may cut down on ADR/litigation demands.
ALTERNATIVE ENFORCEMENT STRATEGIES FOR BOARDS AND MANAGERS
1. Define Violations Clearly in the Rules Associations facing frequent or egregious violations should consider adopting new rules to define what constitutes a “single”, “recurrent”, and “continuing” violation. For example:
• Clarify that each day a prohibited short-term rental occurs is a separate violation.
• Declare that ongoing physical violations (e.g., unapproved architectural modifications) are considered continuing violations.
Rules adopted through the 28-day comment process and member participation are generally given deference by courts unless they are unreasonable or in direct conflict with the law.
(See Friars Village.)
2. Leverage Health & Safety Concerns AB 130 preserves broader fining authority where health and safety concerns are involved. Associations should consult counsel to identify violations that plausibly fall under this exception.
3. Pursue Alternative Enforcement Tools
Where fines may be ineffective, associations can turn to alternative remedies, such as:
• Self-help remedies
Entering the property to perform needed maintenance and assessing the cost to the owner, if permitted by the CC&Rs.
• Suspension of rights
Temporarily suspending amenity access rights.
FINAL THOUGHTS
Until the courts or Legislature provide more definitive guidance, associations must navigate AB 130 with care and creativity. Boards should adopt policies, document enforcement decisions, and ensure due process is always followed. The $100 cap is not the end of HOA enforcement— but it does demand a more nuanced, strategic approach to maintaining community standards.
Consulting legal counsel when drafting rules or developing enforcement policies is more important than ever. With proper planning, boards can still preserve property values and community harmony in this new era of compliance.
The $100 cap is not the end of HOA enforcement—but it does demand a more nuanced, strategic approach to maintaining community standards.
William
Curry, Esq. and Warren Katz, Esq. are attorneys with Whitney | Curry APC specializing in general counsel work with HOA’s and Commercial Associations. The firm is located in Lake Forest, California.
AB 130 NEW RULES FOR ENFORCING FINES
By Mark T. Guithues, Esq.
When Governor Newsom signed AB130, his intent was to fund California’s annual budget. Oddly, this year’s State budget funding bill included language from another draft bill (SB 681), which proposed capping HOA fines at $100 for non-health and safety violations and eliminating the penalty if the behavior or condition is “cured” before the board’s hearing.
Prior to AB 130’s passage, the author of SB681 (Senator Wahab) acknowledged definitional shortcomings in his bill and was negotiating clarifying language with the HOA industry. However, funding bills are effective immediately, and this is now California law!
To start the discussion on how best to implement AB 130 for California’s 50,000 community associations, we offer draft language in a PROPOSED ENFORCEMENT AND FINE POLICY OVERLAY (attached hereto), designed to overlay most HOA enforcement policies and rules. The non-highlighted language reflects the least controversial application of the statute. Conversely, the highlighted language defines the statutes’ “elephants-in-the-room” which are the missing definitions of “violation”, “cure” and “health and safety.”
A board’s decision to utilize the highlighted language increases the risk of legal challenge. The Corporations Code and an association’s governing documents typically authorize boards to adopt definitions to fill holes left by the Legislature. But the further we go, the greater the risk that a judge disagrees – and California’s prevailing parties’ fees can turn that risk into a very expensive gamble. So, the highlighted language is offered not as a “plug and play” solution, but as discussion points between a board and its legal counsel – to be revised and modified to fit the community and its appetite for legal risk.
In paragraph 2, fines for Minor Violations shall not exceed $100 per violation. We think “violation” means each instance in which a governing document is not followed. For example: failing to submit a required application, improperly storing an RV, or failing to undertake proper maintenance of landscaping is a single $100 violation. Serially recurring transgressions, like violating overnight parking restrictions each night, then leaving each morning is a $100 Minor Violation each time.
COMMENT
This language honors the Legislature’s elimination of escalating fines and allows such fines only where the situation recurs anew each day. Note: It is possible that the Legislature intended to disallow daily fines under all circumstances.
PROPOSED ENFORCEMENT AND PURSUANT TO CIVIL CODE SECTIONS Effective _________,
Pursuant to California Corporations Code section 7231 and the Association’s Governing Documents, the Association’s Board of Directors sets forth the following definitions as necessary to implement an operable Enforcement and Fine Policy. This Addendum is a Rule and Regulation and a Governing Document as defined in California Civil Code section 4150. The following is added to and shall supersede any conflicting rules and regulations and any previously published enforcement or fine policy:
1. Violations shall generally be divided into two categories: (a) violations unlikely to result in adverse health or safety impacts on the common area or another member’s property (“ Minor Violations”); and (b) violations which “may result in an adverse health or safety impact on the common area or another association member’s property” (“ Major Violations”).
2. Fines for Minor Violations shall not exceed $100 per violation. “ Violation” means each instance in which a Governing Document is not followed. For example: failing to submit a required application, improperly storing a RV, or failing to undertake proper maintenance of landscaping is a single $100 violation. Repeating transgressions like violating overnight parking restrictions each night, then leaving each morning, is a $100 Minor Violation each time.
3. If a violation is a Major Violation, the dollar value of the Fine shall be determined by the Board in a written finding at a Board meeting open to the members. (The disciplinary hearing with the member may be held in executive session.) Depending on the severity of a Major Violation, the Fine may be assessed as follows: (a) the stated amount in the existing violation schedule; or (b) up to One Thousand Dollars ($1,000.00) per violation.
4. Examples of Major Violations may include but are not limited to:
a. Use of E-bikes in pedestrian areas or areas within the Association that are outside of those areas marked with appropriate signage authorizing use of E-bikes;
b. Blocking emergency vehicle access or fire lanes;
c. Disabling safety features such as smoke detectors, fire alarms, or sprinklers;
d. Unauthorized construction that compromises structural safety;
e. Exceeding the speed limit within the community’s streets; or g. Other violations the Board, in its discretion, determines may result in a health and safety issue.
5. Cure. If a member “cures” a violation prior to the hearing, the Board may not impose the fine. “Curing” means (a) remedying the violation (for example: executing and submitting an ignored architectural application, undertaking maintenance of unkempt landscape or signing an agreement not to repeat the violation); or (b) actually not repeating the violation (for example, leaving for work each morning does not “cure” violating overnight parking restrictions; nor does leaving a Board meeting “cure” swearing at or threatening directors).
FINE POLICY OVERLAY
SECTIONS 5850 AND 5855
_________, 2025
6. Financial Commitment.
If a member provides a ‘financial commitment” to cure the violation, the Board may not impose a Fine. A “ financial commitment” means (a) a written agreement with the Association; (b) providing the Association with a copy of an executed contract with a licensed contractor to complete repair of damage within 30 days of the hearing; or (c) both. Additional curing time may be granted based on the scope of repair. Note: for reasons of insurance and warranty, members may not effect repairs to the common area.
7. Legal and Administrative Costs.
Suspension of privileges, towing or reimbursement of legal fees and administrative costs incurred in gaining compliance as permitted by the Governing Documents or California law are not Fines. Legal and administrative costs incurred in gaining compliance are permitted by these Governing Documents.
8. Notice of Meeting.
If the Board meets to consider imposing a Fine, the Board shall notify the member in writing of the date, time and place of the hearing meeting at least 10 days prior to such hearingwhich notice shall be delivered to the member by personal or individual delivery as defined in Civil Code section 4040.
9. Agreement.
If the Board and member reach an agreement during such hearing, the Board shall draft a written resolution. A written resolution signed by the Board and the member which is not in conflict with the law or the Governing Documents shall be binding on the Association and is judicially enforceable.
10. Notice of Decision.
If the Board imposes a Fine on a member, the Board shall provide the member with written notification of the decision by either personal or individual delivery within 14 days following such Fine hearing. No late charge or interest shall be charged to a member for a Fine.
11. Right to IDR.
If the Board and member are not in agreement after such meeting, a member may request Internal Dispute Resolution (“IDR”) per Civil Code section 5910.
12. Annual Disclosure.
The Association shall provide a copy of the most recently distributed schedule of Fines/monetary penalties and any supplements thereto to any member upon request and shall also include distribution of same in its Annual Policy Statement prepared pursuant to Civil Code section 5310.
13. A Reimbursement Assessment for costs incurred by the Association to repair damage to the common area and common facilities caused by a member or the member’s guest or tenant per Civil Code section 5725(a) is not a Fine or penalty per Civil Code section 5855 and shall be in the full amount of the Association’s out-of-pocket expenses to repair the damage.
Paragraph 5 discusses Cure. If a member “cures” a violation prior to the hearing, a board may not impose the fine. We think “curing” means (a) remedying the violation (for example: executing and submitting an ignored architectural application, undertaking maintenance of unkempt landscape or signing an agreement not to repeat the violation); or (b) not repeating the violation (for example, leaving for work each morning does not “cure” violating overnight parking restrictions; nor does leaving a board meeting “cure” swearing at or threatening directors thereat).
In paragraph 6, if a member offers to in cure the violation, the Board may not fine. We think a “ financial commitment” means (a) a written agreement with the association; (b) providing the association with a copy of an executed contract with a licensed contractor to complete repair of damage within 30 days of the hearing; or (c) both.
COMMENT
By not defining the word “cure” the Legislature left open the proposition that by simply stopping the behavior, any penalty can be erased. Imagine receiving a ticket for speeding 80mph on the freeway, but the judge is unable to assess the fine because (as you stand in court) you are no longer speeding! Defining “cure” with the highlighted language means if a violation is cured; the board should not need to seek further enforcement. Conversely, if the board needs to seek further enforcement, then the issue was never really “cured.” Note: although illogical, it remains possible that the Legislature fully intended to encourage recidivism by allowing “cure” to erase any and all past violative behavior(s).
COMMENT
By not defining the words “financial commitment,” the Legislature left open the proposition that an owner can simply make a verbal commitment – a promise to pay for all costs of repair - immediately freezing a board’s ability to effect timely repairs using a licensed professional. We believe the highlighted language honors the Legislature’s desire to allow owners to promptly maintain or repair their property, without penalty.
HOW WILL THIS AFFECT ENFORCEMENT?
Practically speaking, using escalating or daily fines to resolve legal conflicts before proceeding to ADR (then court action) has been eviscerated as a useful tool to resolve common enforcement issues.
DID THIS JUST DESTROY THE ENFORCEMENT PROCESS?
Absolutely not. In most cases, your community presently starts enforcement with a standard courtesy notice identifying the violation, followed a month or so later with a notice calling the owner to a fine hearing - either at $100 or the full amount identified on the fine schedule if the board’s found a health or safety (Major) violation. Now, instead of a third notice and escalating fines, the Legislature has incentivized HOAs to escalate to ADR, followed by a lawsuit.
Mark T. Guithues, Esq. is the founder of Community Legal Advisors Inc, a law firm providing assessment collection and general counsel services to community association clients, subdivision services to developer-declarant clients and mediation and arbitration services to homeowner clients.
Let the “Health and Safety” Exception Take You Home
By A.J. Jahanian, Esq.
In the ever-evolving landscape of homeowners’ association (“HOA”) legislation, Assembly Bill 130 (“AB 130”), signed into law in 2025, represents a significant shift in how HOAs can impose monetary penalties for violations of governing documents. This change aims to protect homeowners from excessive penalties while promoting fairness in community governance. However, the law includes a crucial exception for violations that may result in “adverse health or safety impacts” on common areas or other members’ properties. This carve-out provides boards and managers with a powerful tool to enforce rules more robustly when community well-being is at stake.
For community managers and HOA boards, the $100 fine limitation could undermine the ability to deter serious infractions, potentially leading to lax compliance and increased disputes. Yet, by strategically leveraging the health and safety exception, associations can preserve higher fine structures for violations that truly matter. The key lies in adopting a well-crafted enforcement policy and fine schedule that defines “health or safety” violations in a way that is both broad enough to cover a range of issues and specifically tailored to withstand scrutiny.
Understanding the $100 Cap and Its Exception Prior to AB 130, HOAs were afforded flexibility in setting fine amounts through their governing documents, often escalating penalties for repeated or egregious violations. Now, under Civil Code § 5850(c), fines are limited to the lesser of the amount listed in the association’s schedule or $100 per violation. This applies to all monetary penalties for breaches of rules, covenants, or restrictions, including those related to guests or tenants.
The exception, outlined in § 5850(d), allows boards to impose higher fines—as specified in their pre-existing or updated schedule—if the violation “may result in an adverse health or safety impact on the common area or another association member’s property.” This provision recognizes that not all violations are equal. A minor aesthetic infraction, like an unapproved mailbox color, might warrant only a $100 fine, but something posing real harm—such as improper waste disposal leading to pest infestations—demands stronger deterrence. By focusing on this exception, HOAs can “work around” the cap without violating the law, maintaining community standards while complying with the new restrictions.
Crafting an Effective Enforcement Policy and Fine Schedule
To maximize the utility of the “health and safety” exception, HOA boards should promptly review and revise their enforcement policies and fine schedules. The goal is to define “adverse health or safety impacts” in a manner that is strategically broad, capturing a wide array of potential risks, yet specific enough to provide clear guidance and defend against challenges.
Start by incorporating language that broadly interprets “health or safety” based on common-sense standards. For instance, “broad” health or safety categories might include any action or omission that could reasonably lead to physical harm, disease transmission, environmental hazards or structural damage affecting shared spaces or neighbors. This broad umbrella allows flexibility but pairing it with strategically specific examples will also illustrate application and help ensure consistent enforcement.
The fine schedule can then tier penalties accordingly. For non-health/safety violations, the cap is $100 as
required by AB 130. For qualifying exceptions (i.e., health or safety category violations), the schedule can retain or establish higher amounts (e.g., $200–$500 for first offenses, escalating repeat offenses, etc.), explicitly linking them to the defined impacts.
Examples of Health and Safety Violations
To make this actionable, consider the following reader-friendly examples of how to define and apply the exception. These are drawn from common HOA scenarios and can be adapted to your community’s needs:
1. Structural and Maintenance Issues: Violations like failing to repair a leaking balcony or pipe could be classified as health or safety risks if they lead to water intrusion, mold growth, or structural instability. Mold can cause respiratory issues, qualifying as an adverse health impact on neighboring units. A policy might specify that any maintenance neglect that promotes mold, pests, or weakens building integrity, potentially harming residents’ health or property safety, may be subject to fines in excess of $100.
2. Fire hazards, i.e., unauthorized storage of flammable materials in garages or common areas pose clear safety risks. Boards can define this broadly as any accumulation of items that increases fire risk or obstructs emergency access; for example, hoarding debris could block fire escapes, endangering lives or risking harm to person and property. Higher fines for these violations may be justifiable under the fine schedule, in order to deter such conduct, including ensuring that pathways aren’t blocked during fire or other emergency evacuation circumstances.
3. Sanitation and pest control may also constitute a health or safety category, such as improper trash handling or pet waste cleanup, which attracts rodents or spreads bacteria. A strategic definition would reference actions leading to unsanitary conditions that may foster disease vectors or contamination. This covers overflowing dumpsters or neglected yards (breeding mosquitoes, attracting wild animals or vermin, etc.). Again, fines above $100 can be enforced for these violations, if effectively spelled out in the enforcement policy and fine schedule
4. Noise and nuisance issues might be more controversial, if boards lump them in with other health or safety violations. Chronic loud noise isn’t always a health issue, but if it disrupts sleep patterns leading to stress-related health problems, it could qualify. An enforcement policy that encompasses excessive noise in its health or safety provisions could allude to “excessive” noise, during quiet hours (for example), leading to unreasonable interference with sleep, peace and quiet enjoyment of neighbors. Of course, boards should first consult with legal counsel to ensure that a noise issue is more than a neighbor-toneighbor dispute, warranting HOA enforcement.
There are certainly many ways to bolster enforcement policies, through health and safety provisions. Fines in excess of $100 must be justified as an adverse health or safety risk, which is supported by the governing documents. At a high level, health or safety violations create the potential for harm to the community (conditions or actions that could reasonably result in property damage or injury), impact community welfare (compromising safety or livability of the community), or deviate from community standards in some way that the board, in its reasonable discretion, determines undermine the health or safety of the community.
What’s Next? Be Proactive!
Boards and managers should collaborate with legal counsel to draft these policies, ensuring they align with governing documents and avoid overreaching that could invite lawsuits. Conduct member education sessions to explain the changes, emphasizing how the exception protects everyone. Track enforcement actions meticulously, documenting findings to build a record of fair application.
In conclusion, while AB 130’s $100 cap curtails traditional fine powers, the health and safety exception offers a lifeline for effective governance. By adopting a forward-thinking enforcement policy with broad yet specific definitions, boards can strategically navigate this limitation, fostering safer, healthier communities. As California’s HOAs adapt, this proactive strategy will prove invaluable in upholding standards without compromise.
Not all violations are equal. Real health or safety risks let HOAs enforce stronger penalties while staying within the law.
With eight years of experience in the industry, A.J. Jahanian, Esq. is an attorney at Beaumont Tashjian and a part of the HOA Legal Counsel.
THE AB130 FINE CAP:
MUCH ADO ABOUT NOTHING?
David F. Feingold, Esq.
AB130’s $100 per-violation cap on fines has sparked a firestorm of debate. But like the characters in Shakespeare’s Much Ado About Nothing, are we making more of this development than it deserves?
This article examines the practical limits of fines and explores the available, and some may argue more effective, enforcement strategies that do not rely on the imposition of fines.
COLLECTING FINES IN THE REAL WORLD
The imposition of fines in many situations is an imperfect remedy. There are three primary reasons for this. First, fines are more difficult to collect because a line cannot be recorded and then foreclosed by non-judicial foreclosure. Rather, to collect the fines, an association must go to court. Second, judges (and especially juries) often view fines with skepticism. If litigation is ultimately necessary, one of the association’s primary objectives will be to be declared by the prevailing party and thereby entitled to recover its fees and costs. If there is an overreach on fines that the judge or jury finds to be unreasonable, the association puts that objective at risk. Finally, consistently levying fines on members may be viewed as punitive and unreasonable, leading to member outrage and, in many cases, bad press.
This is not to say that fines cannot be an effective tool – they can be. Even relatively high dollar fines can be collected depending on the community and the issue involved. That said, there are other strategies and remedies that should be considered to address violations without tripping over the ambiguities of AB130.
ALTERNATIVE STRATEGIES AND REMEDIES
Education and Outreach
For common violations, the effectiveness of an education and outreach initiative should not be overlooked. Community-wide communications that explain the importance of compliance can make a meaningful difference. Related to outreach is the use of the Internal Dispute Resolution process. Designate a director, or a couple of directors, to sit down with the member before taking formal action. If the member refuses to participate, the association will have more evidence of its reasonableness. If they participate, the issue may actually be resolved by constructive, face-to-face communication.
The Call to Hearing
If education and outreach are not effective, a call to hearing is the next step, and is itself a significant enforcement tool. While some members will see it as an escalation to be resisted, many others may see it as a wake-up call.
Continues on page 12
MUCH ADO ABOUT NOTHING
Continued from page 11
Remedies Without Fines
• Notice of Results
A post-hearing notice that includes an accurate and concise finding of a violation and its basis, along with the discipline imposed, is a critical enforcement tool in and of itself. It may just result in compliance by the owner. If it does not, a well-drafted notice of results will serve as the foundation for further enforcement efforts.
• Suspension of Use Privileges
An association cannot suspend rights that are fundamental to ownership, such as access rights or the use of exclusive use common areas. However, an association can suspend an owner’s right to use common area facilities - such as pools, gyms, clubhouses and other amenities. A suspension may carry more weight than a fine for many members.
• Self-Help
In certain circumstances, an association may exercise “self-help” to cure a violation directly— for example, towing an unauthorized vehicle
from a fire lane, removing debris or items from the common area or trimming vegetation that creates a fire hazard. Always consult counsel before invoking self-help, but do not dismiss the option. It can be a cost-effective and expedient way to resolve violations in situations where it is clearly authorized and where the risk of conflict while the self-help is carried out is minimal.
• Reimbursement Assessment
Reimbursement assessments allow an association to recover the actual costs incurred as a result of a violation. Because these charges are not monetary penalties, the cap on fines arguably does not apply. (Subsequent caselaw may provide further clarification as to whether reimbursement assessments are also subject to the restrictions set forth in AB 130) Moreover, if they are treated as regular assessments under the association’s governing documents, collection can proceed via the lien and nonjudicial foreclosure process. Extra services charged by community managers and staff
AB130’S $100 FINE CAP REMINDS ASSOCIATIONS THAT ENFORCEMENT IS ABOUT FAIRNESS AND ACCOUNTABILITY, NOT JUST PENALTIES.
You can tune in and stream CACMCHAT: The HOA Life on Spotify and Apple Podcasts . Subscribe directly from our website, where you can also submit questions and topic ideas at podcast@cacm.org. If you haven’t tuned in yet, now’s the time—listen and subscribe today!
time may also be included, if authorized by law and the governing documents and carefully documented.
• Request for Resolution
Associations and owners must offer Alternative Dispute Resolution before filing most lawsuits to enforce the governing documents. The process begins with a written Request for Resolution, which invites the other party to settle the dispute in a forum other than a courtroom – typically mediation. As an enforcement tool, the Request for Resolution can be effective to convince violators that it is in their best interest to resolve the violation rather than face the monetary and emotional costs of the litigation process.
• Litigation
Filing a lawsuit is the ultimate enforcement tool. In a perfect world, an association quickly obtains a judgment that permanently resolves
a dispute and requires the violator to reimburse the association’s fees and costs. However, we do not live in a perfect world. The expense, time and unpredictability of litigation, along with the disclosure issues pending litigation may create, should be carefully considered.
SUMMARY
While AB130’s $100 fine cap impacts enforcement options, fines are only one of the many enforcement tools available to associations. Prudent associations will use this moment to reassess their enforcement policies and strategies and shift away from an overreliance on fines toward alternative tools. By doing so, associations can maintain compliance, protect community standards and demonstrate that their goal is not punishment, but fairness and accountability.
David F. Feingold, Esq. is a partner at the San Rafael law firm of Ragghianti Freitas LLP, and has represented common interest developments in the Bay Area since 1986.
Understanding AB130’s New Fee Restrictions on ADUs
By Cyrus Koochek, Esq.,
Over the past several years, California has enacted numerous laws aimed at expanding affordable housing opportunities. Many of these laws have directly impacted community associations, including the removal of barriers to the installation of accessory and junior accessory dwelling units (ADUs) by homeowners. Regardless of one’s opinion of these laws, understanding the extent of permissible actions by associations remains essential.
AB130 isn’t just about fines - it also reshapes the rules for Accessory Dwelling Units, banning any fees or financial requirements.
One of these laws is AB130, an all-encompassing budget bill signed into law with immediate effect on June 30, 2025. Many people assume AB130 only impacts disciplinary hearings and monetary fines, including the now notorious $100 cap on fines for specific violations. However, this is not the case. AB130 also introduced a substantial modification concerning Accessory Dwelling Unit (ADU) construction. Specifically, the legislation explicitly clarifies that the “reasonable restrictions” permissible on an ADU must not encompass any fees or other financial obligations.
Interestingly, AB130 did not directly amend the DavisStirling Act; however, California Civil Code §714.3, which was amended, still directly governs the construction of ADUs in lots zoned for single-family residential use, such as planned developments. §714.3 is essentially identical to California Civil Code §4751, which is a part of the DavisStirling Act. Why the Davis-Stirling Act was not amended as well is unclear, and it may be an oversight by the state legislature; however, it does not change the fact that homeowners seeking to install ADUs within associations are protected by AB 130.
Associations have historically been authorized to impose “reasonable restrictions” on ADU development, which are defined as restrictions that do not impose an unreasonable increase in construction costs or effectively prohibit the construction of ADUs. AB130 further expands the definition by stipulating that reasonable restrictions shall not encompass any fees or other financial requirements.
For managers, a practical takeaway, stemming from AB130, is to collaborate proactively with your boards and to meticulously tailor application fees.
At first glance, the language appears to be clear. It might be tempting to assume that an association would never impose any form of fee or financial obligation when reviewing an architectural application involving an ADU. However, this interpretation is overly broad. The legislative intent was to eliminate barriers that render ADUs financially prohibitive from a construction perspective, rather than to prevent associations from recovering legitimate costs related to reviewing or approving work unrelated to the ADU itself. The statute prohibits fees solely attributable to the construction of the ADU, but it does not preclude associations from charging fees for applications in general, expert-related fees or for broader modifications submitted within the same application.
This constitutes a significant distinction. ADU projects are inherently structural, and they may necessitate the engagement of an association, which may depend on an architect or other specialists to facilitate the review process of the application. Associations are still permitted to levy fees to recover expenses related to expert review, provided that such authority is outlined in the governing documents and that these fees would have been imposed regardless of whether the building improvement pertains to an ADU.
Furthermore, numerous ADU projects encompass more than merely the ADU itself. Additional enhancements, such as landscaping, fencing, hardscaping, exterior modifications or the relocation of utilities, are also frequently involved. These fall within the standard architectural review authority of the association and are subject to any applicable fees. Deposits for ADU projects are also likely enforceable, provided they are mandated for all significant or similar architectural endeavors, and the ADU project is treated consistently with others. Ultimately, associations should retain the ability to recover costs associated with legitimate review activities that are part of the standard architectural process, irrespective of whether they pertain to ADU projects or not.
According to the current legal framework, there are two actions that associations should refrain from undertaking; however, associations are advised to consult
their legal counsel directly when establishing policies concerning ADUs. First, associations must not impose a fee solely on the basis that an application pertains to an ADU. Charging a fee merely because the application involves an ADU would constitute a violation of the law. Furthermore, establishing or levying an ongoing assessment on owners with ADUs is also likely to contravene AB130.
For managers, a practical takeaway, stemming from AB130, is to collaborate proactively with your boards and to meticulously tailor application fees. A comprehensive and well-drafted set of architectural guidelines, addressing review procedures, application processes, and expert fees, will considerably aid in safeguarding an association’s interests and establishing a defensive posture should an owner challenge the fees imposed by the association. For communities that have not previously received an ADU request, it is imperative to adopt ADU and related guidelines and ensure thorough preparedness; otherwise, owners may contend that any guidelines or requirements you impose are arbitrary and unenforceable.
In spite of the preceding considerations, it is imperative that boards and managers exercise caution in the implementation of architectural fees, especially when accessory dwelling units (ADUs) are involved. The limitations inherent in the new legislation remain untested and may be subject to future litigation or judicial interpretation. Consultation with legal counsel is therefore of utmost importance for communities where ADU installations are anticipated. Such legal counsel serves to safeguard associations and ensures that boards operate in accordance with the business judgment rule, which is essential for fulfilling their fiduciary duties to the association.
AB130 should be regarded not as an outright prohibition on fees, but rather as a directive to ensure that any costs imposed are justified by factors beyond merely the fact that an architectural application involves an ADU.
With 13 years in the industry, Cyrus Koochek, Esq., CCAL, is an attorney at SwedelsonGottlieb specializing in Community Association Law in the Los Angeles and San Francisco area.
By Karyn A. Larko, Esq.
INVESTIGATING GOVERNING DOCUMENT VIOLATIONS
Governing documents for associations grant the board the power, and in many cases, the obligation, to enforce the governing documents. However, even when the governing documents do not expressly impose a duty to enforce them, California courts have found that associations, via their boards, have the primary responsibility for enforcement. The courts have also found that associations and, in some cases, their board members personally, may be held liable for failing to enforce the governing documents. There may be circumstances that support a board’s decision not to enforce the governing documents (e.g., vague language in the CC&Rs, available legal defenses), but in the absence of such impediments, it is expected that an association will be primarily responsible for governing document enforcement.
In addition to having the right and obligation to enforce the governing documents, boards also have a fiduciary duty to their associations. This duty includes a duty of care. Specifically, this means that board members must manage their associations to the best of their ability, discharging their duties in good faith, in a manner they believe to be in the best interests of the association, and with such care, including reasonable inquiry, as an ordinarily prudent person in a similar position would use under comparable circumstances. In the context of governing document enforcement, this means boards have an obligation to undertake a fair and reasonable investigation of alleged violations.
REASONABLE INVESTIGATIONS
What constitutes a reasonable investigation varies depending on the nature of the alleged violation. In matters involving exterior, unauthorized architectural alterations, for example, a reasonable investigation may entail having a director or the manager check the separate interest from the common area to confirm that the alteration exists, and reviewing correspondence between the association and the homeowner to confirm that the alteration was not previously approved by a board or architectural committee.
In other instances, such as recurring alleged noise nuisance complaints, a reasonable investigation may require having one or more directors go to the complainant’s separate interest to independently verify that the noise rises to a nuisance. It may also be appropriate to hire a specialist to evaluate the level of noise. This is especially true for noise complaints associated with alleged flooring violations. Similarly, when it comes to secondhand smoke complaints, it may be appropriate for directors to independently verify whether the amount of secondhand smoke rises to the level of a nuisance and/or hire an expert to measure the smoke present. Other common means of investigating violations include obtaining witness statements and testimony and reviewing footage from association or owner-installed security cameras. For some violations, if authorized by the governing documents, it may be appropriate to inspect the interior of the alleged violator’s separate interest or exclusive use areas. However, this inspection should only be performed if the owner consents or if a court order compels the inspection.
WITH AUTHORITY COMES RESPONSIBILITY.
BOARDS HAVE BOTH THE POWER AND THE DUTY TO ENFORCE THEIR GOVERNING DOCUMENTS.
TIMING OF THE INVESTIGATION AND THE IMPACT OF AB 130
An alleged governing document violation should be investigated prior to calling an owner to a hearing, so as not to waste the boards or owner’s time if there is insufficient evidence to indicate that a violation occurred or that the owner is likely responsible. I say “likely” because at the hearing, the owner must be given an opportunity to present evidence of innocence, and the board must give due consideration to this evidence.
As of of July 1, 2025, California Civil Code section 5855 has been amended to, among other things, prohibit boards from imposing fines and suspensions against an owner for a violation if the owner has cured that violation prior to the hearing. This means that boards and managers now have an obligation to conduct a second investigation prior to the hearing to confirm whether a curable violation has been resolved.
FACILITATING INVESTIGATIONS
To facilitate the investigation process, an association should adopt an enforcement procedure that requires persons reporting violations to provide:
1. Their name and contact information
2. The date and approximate time of the violation
3. A description of the violation, including the location
4. The name and/or address of the violator
5. The names and/or addresses of any other witnesses
QUESTIONING WITNESSES
PRACTICE TIPS
• Confirm that the conduct or circumstance being complained of, if true, constitutes a violation of the rules or CC&Rs before expending time and resources on an investigation.
• When possible, document violations with video or photographs.
• If there is a hostile relationship between the person reporting a violation and the alleged violator, it is especially important to obtain corroborating evidence to ensure a fair hearing.
• Check your governing documents to ensure hearings comply with both California law and your governing documents, as the latter can impose more stringent requirements.
• Ensure that evidence of a violation is retained in case further enforcement action is needed.
Just as the nature of an alleged violation will dictate what constitutes a reasonable investigation, so will the severity of the potential consequences if the violation is confirmed. Generally speaking, the greater the potential consequences to the owner, the more comprehensive the investigation should be— both to ensure the owner is treated fairly and to reduce the likelihood of a successful challenge to any enforcement action.
When unsure about how an alleged violation should be investigated or the level of investigation that should be undertaken, it is best to consult with the association’s attorney.
When questioning possible witnesses to an alleged violation, it is important to keep the identity of the alleged violator confidential to the extent possible. Further, in the event the alleged violator is a minor, the nature of the alleged violation should also be kept confidential. For example, rather than asking a possible witness whether they heard Owner X harassing Owner Y by the pool on a specific date, ask : “Did you witness any concerning conduct by the pool on this date? If so, what did you witness, and who was involved?” This helps ensure a fair investigation and protects the privacy rights of the alleged violator.
On a related note, witnesses should be notified that it may not be possible to keep their identity confidential, since the defendant owner is entitled to know the evidence against them. It may be necessary for witnesses to testify or submit a declaration in the event of litigation. Moreover, some governing documents give defendant owners the right to call and crossexamine witnesses at board hearings.
• When unsure about how an alleged violation should be investigated or the level of investigation that should be undertaken, consult the association’s attorney.
Karyn A. Larko, Esq. is an attorney at Epsten APC based out of San Diego, California. Larko specializes in community association counsel with 17 years of experience in the industry.
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FELDSOTT, LEE & NICHTER, ATTORNEYS AT LAW
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Stanley Feldsott, Martin Lee, and Austin Nichter
Laguna Hills, California
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THE JUDGE LAW FIRM
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UNITED TRUSTEE SERVICES
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ATTORNEYS
ADAMS | STIRLING PLC
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BERDING | WEIL
Construction Defect Attorneys
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spowell@berdingweil.com www.berding-weil.com
BRISCOE IVESTER & BAZEL LLP
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mkao@briscoelaw.net www.briscoelaw.ne/
COMMUNITY LEGAL ADVISORS, INC.
General Counsel & Assessment Collections
Mark Guithues, Esq., Laurie Masotto, Esq., Jeffrey Speights, Esq., Jay J. Brown, Esq. Inland Empire, Orange County, San Diego County 509 N. Coast Hwy. Oceanside, CA 92054 (760) 529-5211 • Fax (760) 453-2194 mark@attorneyforhoa.com www.attorneyforhoa.com
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EPSTEN, APC
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Jon Epsten, Esq. & Susan Hawks McClintic, Esq. San Diego | Coachella Valley | Inland Empire 3111 Camino del Rio North, Ste. 560 San Diego, CA 92108 (858) 527-0111 • Fax (858) 527-1531 info@epsten.com www.epsten.com
FIORE RACOBS & POWERS, A PLC
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Association Law, Assessment Collections, General Counsel
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HUGHES GILL COCHRANE TINETTI, PC Community Association & Construction Defect Law
John P. Gill, Esq. l Amy K. Tinetti, Esq. 1350 Treat Blvd., Ste. 550 Walnut Creek, CA 94597 (925) 926-1200 • Fax (925) 926-1202 atinetti@hughes-gill.com www.hughes-gill.com
THE JUDGE LAW FIRM
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Providing General Counsel & Collection Services Throughout CA for Over 20 Years
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LOEWENTHAL, HILLSHAFER & CARTER, LLP
Community Association Law I Construction Defect Litigation
David A. Loewenthal I Robert P. Hillshafer
Los Angeles, Ventura & Surrounding Counties
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MCGLINCHEY STAFFORD
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PRATT & ASSOCIATES, APC
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Sharon Glenn Pratt Los Gatos, CA 634 North Santa Cruz Ave, Ste. 204 Los Gatos, CA 95030 (408) 369-0800 Fax (408) 369-0752 spratt@prattattorneys.com www.prattattorneys.com
RAGGHIANTI FREITAS LLP
General Counsel and Mediation
David F. Feingold, Esq. Serving Bay Area Communities Since 1986 1101 Fifth Ave., Ste. 100 San Rafael, CA 94901 (415) 999-7635 dfeingold@rflawllp.com www.rflawllp.com
RICHARDSON | OBER LLP
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SWEDELSONGOTTLIEB
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TINNELLY LAW GROUP
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WOLF, RIFKIN, SHAPIRO, SCHULMAN & RABKIN, LLP
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CONSTRUCTION DEFECT ANALYSIS
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FENTON GRANT KANEDA & LITT, LLP
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HENNIGH LAW CORPORATION
Construction Defect Litigators & Trial Attorneys
Aaron Ehrlich, Esq., Scott Hennigh, Esq., Garrett Mott, Esq.
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RILEY I PASEK I CANTY I SELTZER LLP
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