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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

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34
to avoid local eviction regulations was within the reservation of
local authority to regulate the grounds for eviction under Civil
Code section 1954.53, subdivision (e). (SFAA 2022, at p. 294.)
And in “Mak, the court upheld a local measure limiting the initial
rent of a new tenant where the previous tenant vacated the unit
after the landlord took action to terminate the tenancy with a bad
faith assertion of the landlord’s intent to occupy the premises.
(Mak, supra, 240 Cal.App.4th at pp. 69-70.) The court
determined that the regulation acted as a sanction for landlords’
misuse of landlord-move-in notices to displace tenants so rent
could be raised under the Costa-Hawkins Act’s vacancy decontrol
provisions and, so viewed, was ‘ “a permissible regulation of ‘the
grounds for eviction’ ” ’ within the meaning of Civil Code section
1954.53, subdivision (e). (Mak, at p. 69.)” (Pasadena, supra,
117 Cal.App.5th at p. 239.)
       Under the Relocation Assistance Ordinance, as with the
relocation assistance measure in Pasadena, “a landlord’s
requirement to provide relocation assistance is not limited to
instances where the landlord raises the rent in bad faith in order
to force tenants to move out, but rather applies to all lawful
increases of the rent to fair market value.” (Pasadena, supra,
117 Cal.App.5th at p. 240.) The Relocation Assistance Ordinance
“imposes a categorical infringement on a landlord’s right under
the Costa-Hawkins Act to set rent on an exempt unit at” fair
market rates. (Pasadena, at p. 234.) “The relocation assistance
requirement is thus distinguishable from the ordinance in [SFAA
2022] that was solely concerned with bad-faith, coercive conduct
by landlords. And unlike the measure at issue in Mak, the
relocation assistance requirement is not geared toward
preventing pretextual evictions intended to circumvent rent