Cal. Apartment Assn. v. City of Pasadena (2025)

Citation: Cal. Apartment Assn. v. City of Pasadena (2025)
Parent Document: Cal. Apartment Assn. v. City of Pasadena (2025)
Jurisdiction: California (state)
Effective Date: 2025-12-18
Original Source: https://www.courtlistener.com/opinion/10761039/cal-apartment-assn-v-city-of-pasadena/ ↗

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directly conflicts with the statutory scheme containing the
savings clause.’ ” (Coyne, at p. 1231; see Action Apartment,
supra, 41 Cal.4th at p. 98 [characterizing as “narrowly focused”
the savings clause of the Costa-Hawkins Act’s vacancy decontrol
provisions].)
       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 IV, 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.
       In Bullard, supra, 106 Cal.App.4th at page 491, the court
rejected the argument that an ordinance restricting the rent a
landlord could charge for a replacement unit after the tenant was
evicted for an owner move-in constituted regulation of a “ground[]
for eviction” for purposes of the analogous savings clause under
the Costa-Hawkins Act’s vacancy decontrol provisions. (See Civ.
Code, § 1954.53, subd. (e).) The court explained, “The ground for
eviction was that Landlords sought to recover possession of a unit
for use as their principal residence. The requirement that they
offer another unit at a regulated rent was a condition imposed by
the rent control ordinance on their recovery of possession, but it

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