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effectuate the law’s purpose. We first examine the statutory language, giving it a plain and
commonsense meaning. We do not examine that language in isolation, but in the context of
the statutory framework as a whole in order to determine its scope and purpose and to
harmonize the various parts of the enactment. If the language is clear, courts must generally
follow its plain meaning unless a literal interpretation would result in absurd consequences the
Legislature did not intend. If the statutory language permits more than one reasonable
interpretation, courts may consider other aids, such as the statute’s purpose, legislative history,
and public policy.’ [Citation.]” (Bruns v. E-Commerce Exchange, Inc. (2011) 51 Cal.4th 717,
724.) Courts also look to legislation upon the same subject, which “can serve as important
guides, because our search for the statute’s meaning is not merely an abstract exercise in
semantics.” (MacIsaac v. Waste Management Collection & Recycling, Inc. (2005) 134
Cal.App.4th 1076, 1084.)
A cause of action for unlawful detainer is a summary proceeding designed to provide an
expeditious remedy to recover possession of real property. (Coyne v. De Leo (2018) 26
Cal.App.5th 801, 805.) The standard elements of an unlawful detainer action for nonpayment
of rent are (1) the tenant is in possession of the premises, (2) the tenant is in default for
nonpayment of rent, (3) the tenant has been properly served with written notice to pay rent or
quit of no less than three days, and (4) the tenant’s default continues after the three-day notice
period has elapsed. (Code Civ. Proc., § 1161, subd. (2); Bawa v. Terhune (2019) 33
Cal.App.5th Supp. 1, 5-6.) Due to the summary nature of the proceeding, strict compliance
with the statutory requirements is a prerequisite to a landlord’s recovery of possession. (Dr.
Leevil, LLC v. Westlake Health Care Center (2018) 6 Cal.5th 474, 480.)
A municipality may, under its general police powers (Cal. Const., art. XI, §7), enact
additional regulations to the grounds for eviction to the extent it is not preempted by state law.3