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DRAFT FOR ATTORNEY REVIEW — NOT FINAL

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

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31
       The relocation assistance requirement does not
concern the regulation of a “basis for eviction.” (Civ.
Code, § 1954.52, subd. (c).) A “basis for eviction” is
properly understood as a ground or reason for
eviction, such as a breach of the tenant’s duties to the
landlord or the landlord’s withdrawal of the unit from
the rental housing market. (See Birkenfeld, supra,
17 Cal.3d at pp. 147-148; [SFAA 2024], supra,
104 Cal.App.5th at pp. 1224-1225, 1235.) The
requirement for a landlord to pay relocation
assistance when a tenant must vacate the unit in
response to a lawful rent increase is not a basis for
any eviction. And although the tenant’s failure to
pay the increased rent would constitute a basis for
eviction (see Code Civ. Proc., § 1161, subd. (2)), as
discussed, the Costa-Hawkins Act prohibits local
regulation that conflicts with a landlord’s right to
impose the rent increase.