1
Plaintiff Colonial Manor, Inc.1 appeals an unlawful detainer judgment entered in favor of
defendant Vilma Reyes, following a court trial adjudicated on stipulated facts. It is plaintiff’s
contention the trial court erred in its determination that the Santa Monica Rent Control Charter
Amendment (“SMRCCA”) was not preempted by Civil Code section 1954.53 (part of the
Costa-Hawkins Rental Housing Act (“Costa-Hawkins”)), and that following the death of
defendant’s spouse—the original tenant—the rent increase was unlawful under the SMRCCA.2
Affirming the judgment, we conclude that defendant was an at-will tenant pursuant to an
implied tenancy, and that defendant was protected by the SMRCCA which was not preempted.
BACKGROUND
On March 14, 2024, plaintiff filed a complaint against defendant alleging a cause of
action for unlawful detainer, seeking possession of a rental property located in the City of Santa
Monica (“City”). The complaint alleged that on January 3, 2017, defendant agreed to rent the
premises under an oral month-to-month tenancy, for rent of $3,500 per month;3 on March 5,
2024, plaintiff caused to be served upon defendant a three-day notice to pay past due rent of
$3,500 for the month of March 2024 or quit the premises; and, as of March 8, 2024, defendant
failed to pay the rent due or quit the premises. Defendant’s answer denied certain provisions of
the complaint and alleged affirmative defenses, including violations of the SMRCCA.4