April 23, 2026
Appellate Division of the Superior Court, County of Los Angeles
The Rule of Colonial Manor, Inc. v. Vilma Reyes is that a surviving spouse who occupied a rent-controlled unit as a lawful occupant with the landlord's knowledge becomes an at-will tenant by implied agreement upon the original tenant's death and remains protected by local rent control ordinances, under circumstances where the spouse lived in the unit for at least one year before marriage, the landlord was aware of the occupancy, and no sublease agreement existed between the spouses.
April 17, 2026
Court of Appeal of the State of California, First Appellate District, Division Four
The Rule of Western Manufactured Housing Communities Association v. City of Santa Rosa is that during a declared state of emergency, Penal Code section 396's definition of "rental price" for rent-controlled mobilehome spaces occupied at the time of the emergency declaration refers to the rental amount authorized under the local rent control ordinance at the time of the emergency declaration, not at any given time thereafter, and mobilehome park owners cannot "recoup" suppressed rent increases by using those increases as a baseline for post-emergency rent calculations, under circumstances where rent-controlled mobilehome spaces are subject to both local rent control ordinances and section 396's 10-percent cumulative cap during a multi-year emergency declaration.
4/15/26
Court of Appeal of the State of California, Second Appellate District, Division Seven
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.
April 23, 2026 (Modified May 19, 2026)
Appellate Division of the Superior Court, County of Los Angeles
The Rule of Colonial Manor, Inc. v. Vilma Reyes is that a landlord cannot enforce an unlawful detainer for rent that exceeds local rent control ceilings, even against a surviving spouse who becomes an implied tenant after the original tenant's death, under circumstances where the spouse was a long-term lawful occupant known to the landlord and Costa-Hawkins does not preempt local rent control protections for implied tenancies.