California Has 105 Cities Where Even the Cheapest Homes Cost $1 Million. If You Co-Own One of Them, That Equity Isn't Yours Until You Can Actually Sell.

Editor's note: This post draws on a June 2026 Zillow analysis reported by Axios showing that 242 U.S. cities now have million-dollar starter homes — California accounts for 105 of them, more than double any other state. The underlying data referenced throughout can be found at: https://www.axios.com/2026/06/20/starter-home-price-map-million

Here is a fact that should change how you think about a co-ownership dispute in California: Zillow now classifies 105 California cities as having million-dollar starter homes — meaning the least expensive properties available in those markets, the bottom third of inventory, carry price tags above $1 million. That number has tripled since before the pandemic. New York, the second-closest state, has 41 such cities. California has 105.

The appreciation embedded in those numbers is real. But appreciation only helps you if you can sell.

If you co-own property in one of those markets and the other owner won't cooperate with a sale, you are sitting on equity you cannot reach. The asset is there. The value is documented. And none of it is accessible to you until the dispute gets resolved.

That's not a market problem. It's a legal problem — and it has a legal solution.

What a Million-Dollar Starter Home Actually Means for Co-Owners

Zillow defines starter homes as properties in the bottom third of local home values. When Zillow's senior economist describes 242 U.S. cities with million-dollar starter homes as a "cautionary tale about insufficient supply," she's pointing to a constraint that affects buyers trying to enter the market.

But for people who already own California real estate — particularly co-owners — that same dynamic creates a very different problem. The homes that were bought together, inherited together, or acquired as investments have, in many cases, appreciated dramatically. That appreciation is locked inside the property. It moves with the market. It shows up on paper.

And when co-owners can't agree on what to do with the property, it stays locked there.

The stakes of a co-ownership dispute scale with the value of the asset. A disagreement over a $200,000 property is a difficult situation. A disagreement over a $1.1 million property — in a city where that's an entry-level home — is a different category of problem. The financial consequences of delay are proportionally larger.

Why Co-Ownership Disputes Are Common in High-Value Markets

Most co-ownership situations don't start as disputes. They start as practical decisions.

In a state where entry-level inventory costs seven figures in 105 cities, many buyers couldn't have entered the market alone. They bought with a partner, a family member, a friend. Some inherited property jointly — a parent's home that was worth far less when the estate was settled than it is today. Others acquired property as investment partners during a period of significant price appreciation and now disagree about whether to sell, hold, or refinance.

Whatever the origin, the pattern that follows is often similar: circumstances change, the co-owners stop being aligned, and the property that made financial sense to buy together becomes the thing neither party can move forward from.

In California's highest-value markets, these situations play out against a backdrop where the asset at stake has appreciated substantially since the arrangement began. One owner wants to realize that gain. The other doesn't — or can't be reached, or simply refuses to engage. The carrying costs continue. The impasse continues. And the equity sits.

What California Partition Law Actually Does

California's partition statutes — codified in the Code of Civil Procedure starting at section 872.010 — give every co-owner of real property the right to seek a court-ordered resolution of a co-ownership dispute. That right does not require the other owner's agreement. It does not require demonstrating fault. In most cases, it is effectively absolute: if you co-own California real property, you have the right to seek partition.

In practice, partition cases resolve in one of two ways. The court can order a physical division of the property — called a partition in kind — but in most residential cases involving a single structure, this isn't feasible. The far more common outcome is a court-ordered sale, in which the property is sold and the proceeds are divided among the owners according to their respective interests.

The Partition of Real Property Act, which California adopted effective January 1, 2023, modified the analysis for certain inherited properties — what the statute calls "heirs property" — by creating a preference for keeping that property within the family before forcing a sale. But for most co-owned California real estate, including property purchased together by unrelated parties or by relatives outside the heirs-property definition, the traditional partition framework applies: any co-owner can seek a sale, and the court generally must grant it.

What a partition action does, in practical terms, is remove the other owner's veto. If one co-owner is refusing to sell, refusing to engage, or simply cannot be located, a partition action provides a legal mechanism for the cooperating owner to force a resolution through the court rather than waiting indefinitely for agreement that may never come.

The Financial Argument for Not Waiting

Co-owners in dispute often frame the decision of whether to pursue legal action primarily as a legal question. It's also a financial one.

Every month a co-ownership dispute remains unresolved is a month in which carrying costs continue to accumulate — mortgage payments, property taxes, insurance, maintenance — often borne disproportionately by the owner who is engaged. It is also a month during which market conditions can shift. California's housing market has been strong, but it has not always been. The same appreciation that makes equity in these properties substantial today is not guaranteed to persist.

In a market where 105 California cities have million-dollar starter homes, a significant portion of the equity held by co-owners in dispute is tied to properties that have appreciated considerably. The difference between resolving a dispute this year and letting it drag into a third or fourth year is not just an abstract measure of time. It can represent material differences in carrying costs borne, market exposure taken on, and access to equity delayed.

Partition law exists to break that holding pattern. It is not a last resort — it is a legal right that exists precisely because the legislature recognized that co-ownership disputes left unresolved cause real harm to the parties stuck in them.

A Note on How Partition Cases Are Handled at This Firm

One practical barrier that keeps co-owners from acting is the assumption that legal representation requires significant upfront expense — particularly when the equity they're trying to access is locked in a property they can't yet sell.

Underwood Law Firm handles qualifying partition cases on a contingency basis through its Win First, Pay Later model: attorneys' fees come from the outcome of the case, not from the client's pocket at the outset. The firm has handled more than 500 partition actions across California and litigates in courts statewide.

If you co-own California real property and want to understand whether partition is an option, contact Underwood Law Firm for a consultation.