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DRAFT FOR ATTORNEY REVIEW — NOT FINAL

Frazier v. Super. Ct. (2022)

Citation
Frazier v. Super. Ct. (2022)
Parent Document
Frazier v. Super. Ct. (2022)
Jurisdiction
California (state)
Effective Date
2022-12-16

Full Text

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         The term “unless” is a subordinate conjunction connecting the dependent clause to the main
clause of the sentence, meaning no termination of tenancy may occur unless it falls under the definition
of for cause or no-fault, as defined by the Ordinance. (See generally Black’s Law Dict. (5th ed. 1979)
p. 1378, col. 1; see also Humane Society of U.S. v. Superior Court (2013) 214 Cal.App.4th 1233, 1251
[dictionary definitions are an appropriate tool to determine the ordinary meaning of statutory
language].)
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         A plain reading of the word “only” in this context is that a tenancy may be terminated based on
owner-occupancy “for no other purpose” than the circumstances enumerated in the remainder of the
Ordinance. (See Black’s Law Dict. (5th ed. 1979) p. 982, col. 2; see also People ex rel. Hamilton v.
City of Santa Barbara (1962) 205 Cal.App.2d 501, 505 [it is presumed the word “only” is placed in a
statute with a purpose].)