Skip to main content
INTERNAL PROTOTYPE — NOT LEGAL ADVICE — DO NOT SEND

Apartment Assn. of Los Angeles etc. v. City of Los Angeles (2026)

Citation
Apartment Assn. of Los Angeles etc. v. City of Los Angeles (2026)
Parent Document
Apartment Assn. of Los Angeles etc. v. City of Los Angeles (2026)
Jurisdiction
California (state)
Effective Date
2026-05-14

Other Sections in This Document (77)

Full Text

1,888 chars
24
deterrent effect of the Relocation Assistance Ordinance seemingly
conflicts with the Costa-Hawkins provisions permitting landlords
to ‘establish the initial and all subsequent rental rates for a
dwelling or a unit.’ Civ. Code, §§ 1954.52, subd. (a), 1954.53,
subd. (a).” Further, it stated that “[d]epending on the specific
factual circumstances the Relocation Assistance Ordinance may
be inconsistent with notions of vacancy decontrol and the free
market.” Nevertheless, the superior court ultimately concluded
the Relocation Assistance Ordinance was saved by the Costa-
Hawkins Act’s preservation of local authority to “regulate or
monitor the basis for eviction” under Civil Code section 1954.52,
subdivision (c), because it regulated “constructive evictions.”
       AAGLA argues, as did the petitioners in Pasadena, that the
relocation assistance requirement frustrates the purpose of Civil
Code section 1954.52, which is to permit landlords to raise rents
on exempt units to fair market value. (See Pasadena, supra,
117 Cal.App.5th at pp. 234-235 [addressing argument that just as
a municipal measure “could not impose a cap on rent increases
for exempt units without running afoul of the Costa-Hawkins
Act, neither may it impose penalties in the form of relocation
assistance to discourage landlords from exercising their right
under the Act to raise the rent on exempt units”].)
       As we concluded in Pasadena, and as the superior court
concluded in this case, “the relocation assistance requirement
does not directly conflict with the right to raise rents, because
nothing in [the Relocation Assistance Ordinance] constrains
landlords from setting the rent on exempt units whenever they
want and at whatever rate they choose.” (Pasadena, supra,
117 Cal.App.5th at p. 235.) But contradiction preemption
principles still apply when local legislation is “inimical to general