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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cannot be deemed in any ordinary sense of the term a ‘ground’ for
the eviction.” (Bullard, at p. 491; see also id. at p. 492 [“Had the
Legislature intended to preserve local authority to control rent
following evictions, we do not believe it would have spoken in
terms of the ‘grounds for eviction,’ which simply do not include
the amount of rent a landlord may charge after evicting a
tenant.”].) Here, the relocation assistance requirement is a
condition imposed on landlords in response to their increasing the
rent in a manner that causes the tenant to vacate the unit. Even
though the requirement applies in conjunction with a landlord
recovering possession of a vacated unit, it alone does not
constitute a “basis” for eviction in any ordinary sense of that
term.
       Respondents contend that the relocation assistance
requirement under section 1806(b)(C) nevertheless falls within
the savings clause because it “regulates the basis for evicting a
tenant who is unable to pay a large rent increase, because that
increase can result in a constructive eviction.” However, the
relocation assistance requirement does not pertain to, much less
regulate, constructive evictions. First, the savings clause refers
to evictions, not constructive evictions, and savings clauses are
typically strictly construed. (Coyne, supra, 9 Cal.App.5th at
p. 1231.) Second, even if we assume the savings clause permits
local regulation of the basis for constructive evictions, we
disagree with the premise that tenants who are displaced
because they cannot pay lawful, good faith rent increases are
“constructively evicted.”
       “An eviction is constructive if the landlord engages in acts
that render the premises unfit for occupancy for the purpose for
which it was leased, or deprive the tenant of the beneficial

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