California Legal Brief

The Rule of SVF Grosvenor Del Rey Corporation v. Schwarz is that when a three-day notice to pay rent or quit offers payment by mail as an option, the notice must include the name, telephone number, and address of the specific person to whom rent is to be mailed, under Code of Civil Procedure section 1161(2).

The Rule of De Paolo is that a terminated resident manager whose occupancy was contingent solely upon employment has no right to continue possession after employment termination and is not entitled to Tenant Protection Act protections, under circumstances where the resident manager's agreement explicitly conditioned occupancy on continued employment and required vacation within 30 days of termination.

The Rule of Apartment Association of Los Angeles County, Inc. v. City of Los Angeles is that a municipal ordinance creating a monetary threshold that must be satisfied before a cause of action for unlawful detainer accrues is a permissible substantive regulation of the grounds for eviction rather than an impermissible procedural limitation on the unlawful detainer statutes, under circumstances where the ordinance does not extend the unlawful detainer timeline, does not prohibit landlords from proceeding under the state statutory timeline, and does not require landlords to take affirmative action before commencing unlawful detainer proceedings.