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Legal Letter Says City Cannot Expand RV Towing Under AB 630

On December 18, attorneys from multiple legal advocacy organizations, including the Legal Aid Foundation of Los Angeles, the Western Center on Law & Poverty, Disability Rights Education & Defense Fund, and the ACLU of Southern California, sent a demand letter to Los Angeles City Attorney Hydee Feldstein Soto warning that the City is preparing to illegally implement AB 630, a recently enacted state law governing the disposal of certain recreational vehicles. The letter demands written confirmation that the City of Los Angeles will not move forward and states that court action will follow if the City proceeds.

The letter centers on Council File 25-1257, a motion introduced by Councilmember Traci Park and adopted earlier this month directing the City Administrative Officer, the Department of Transportation, LAPD, and the City Attorney “to immediately implement AB 630”. According to the letter, the City lacks legal authority to do so.

AB 630 was signed into law by Governor Gavin Newsom in October and takes effect January 1, 2026. As amended in the Legislature, it authorizes only the Counties of Los Angeles and Alameda to establish pilot programs allowing the dismantling, rather than auction, of certain recreational vehicles valued at $4,000 or less that have been towed as abandoned under a specific provision of the Vehicle Code. The statute does not grant implementation authority to cities, including the City of Los Angeles.

The demand letter emphasizes that this limitation is explicit. “The plain language of AB 630 makes it clear that Vehicle Code section 22851.5 only authorizes the Counties of Los Angeles and Alameda to implement the specified pilot program,” the letter states, adding that “the City’s planned implementation of AB 630 is illegal.”

The statute repeatedly refers to counties and includes a legislative finding that a special statute was required because of the unique needs of Los Angeles and Alameda Counties. Under established rules of statutory interpretation, authority granted to specific entities cannot be expanded by implication or local directive. As the letter notes, where statutory language is unambiguous, courts “presume the Legislature meant what it said, and the plain meaning of the statute governs.”

Despite those limits, the City Council adopted a Public Safety Committee report instructing city departments to begin implementation immediately. An amendment by Councilmembers Nithya Raman and Bob Blumenfield adopted on the council floor specified that reporting back to the Housing and Homelessness Committee would not delay enforcement.

Park has been publicly promoting AB 630 for weeks. In legislative update videos to constituents, she has repeatedly described the law as authority for the City to remove and permanently destroy “junk” or unsafe RVs. In a December 13 update, Park said the Council had approved her motion implementing AB 630, which she claimed “finally allows the city to remove and scrap junk RVs valued under $4,000,” adding that “these unsafe vehicles can be removed from the streets for good.”

The LAFLA demand letter directly challenges that framing. It states that AB 630 is written to apply to recreational vehicles towed as abandoned, not to vehicles deemed inoperable or undesirable. Under California law, abandonment is a legal status defined by the absence of any asserted possessory interest, not by a vehicle’s condition, appearance, or maintenance. An inoperable RV may still be actively occupied and used as a residence.

According to the letter, treating inoperability as interchangeable with abandonment vastly expands the statute beyond its text. Nothing in AB 630 authorizes cities to dismantle RVs based on condition alone or to redefine abandonment to include vehicles that are lived in but cannot be repaired. The letter warns that when public officials attempt to direct enforcement outside the authority granted by a comprehensive statutory scheme, they exceed their authority under state law, and that the City’s instruction to “immediately implement AB 630” is ultra vires under the Vehicle Code.

The demand letter was sent on behalf of the CD11 Coalition for Human Rights, a coalition of organizations and individuals in Los Angeles City Council District 11 that advocates for the rights of unhoused people, low-income residents, and tenants. The coalition also issued a public statement warning that the City is “rushing to enforce a policy without a full or accurate understanding of the plain language of AB 630,” and that the law “does not allow the City of Los Angeles to implement this policy, let alone require it to implement it in a way that results in the destruction of people’s homes.” The statement adds that “a vehicle that is someone’s home is not abandoned,” and cautions that policies blurring that distinction “invite serious harm and abuse.”

As an attorney, Park is presumed to understand the distinction between what a statute permits and how broadly it may be framed in public statements. Proceeding based on an interpretation that collapses abandonment into inoperability, the letter argues, not only misstates what AB 630 authorizes but reinforces the conclusion that the City lacks authority to implement the statute at all.

The dispute also places renewed focus on Mayor Karen Bass’s role in advancing AB 630 in Sacramento. While the law was promoted as a narrow response to abandoned vehicles, it is now expected to be used locally to justify rapid enforcement that would permanently destroy vehicle homes without housing alternatives. The disconnect between the statute’s narrow language and the City’s aggressive enforcement posture points to hurried lawmaking driven by political pressure, where legislation is advanced quickly at the state level and only later tested against its actual legal limits.

That pattern echoes the mayor’s withdrawn effort to weaken Measure ULA through state legislation. In both cases, Bass pushed bills through Sacramento that directly affect Los Angeles residents, with limited public debate and with drafting flaws serious enough to undermine the legislation on its face. In both cases, the measures advanced the priorities of local anti-housing, pro-criminalization constituencies while insulating those choices from scrutiny by Angelenos who bear the consequences.

Whether the City now halts implementation or proceeds despite clear statutory limits will determine whether courts, rather than public process, are left to check a growing reliance on state legislation to impose local enforcement policies that criminalize poverty in Los Angeles.

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