NEW COURT DECISION - Requires Notice Changes!

July 14, 2025

     

On June 26, 2025 the California Court of Appeal for the Second District published a ruling that will impact how ALL landlords in California need to prepare and serve their three-day notices to pay or quit.

 

In light of the Eshagian v. Cepeda decision, we are advising that notices include the beginning and end dates of the notice period.

 

This is a conservative approach due to the decision finding the subject notice in the case was defective, in part, because it did not indicate the beginning or the end date of the notice period. Some are of the opinion that stating the service date within the notice is enough to inform the tenant of the notice period. We understand the reasoning for this and it is arguably sufficient. However, we feel that putting specific dates in the notice is a stronger notice. So that is what we are advising you to do.

 

This does require managers to correctly calculate the notice period. 

 

To guide you in correctly calculating your notice period we have created an FAQ Sheet which you can download below.

December 19, 2025
Reminder!
December 19, 2025
This update covers significant legal updates from 2025 that will affect housing providers in the coming year. We cover major laws passed by the California legislature as well as important court decisions and noteworthy local initiatives. California Legislature AB 246: Eviction Protection for Interruption of Social Security Benefits. AB 325: Common Pricing Algorithm Restrictions. AB 414: Updated Procedures for Returning Security Deposits. AB 628: Stove and Refrigerator Added to Habitability Standard. AB 747: Changes to Service of Unlawful Detainer Lawsuit AB 1414: Tenant Right to Opt Out of Internet Plan. AB 1529: Simplification of AB1482 Disclosure Requirement. SB 610: Post-Disaster Obligations for Landlords, and Tenant Right to Return to Repaired Units. AB1248: Ban on Ratio Utility Billing – Not Passed. Notable Court Decisions Eshagian v. Cepeda (C.A. 2nd, June 26, 2025): Invalidated a 3-day pay-or-quit notice for lacking service date and clear deadline. Gogal v. Deng (C.A. 4th, July 22, 2025): Lease caps on attorney fees/costs ($1,000) enforceable, but California Supreme Court has agreed to review decision. Ongoing COVID Eviction Moratorium litigation. Local Initiatives Los Angeles: Immigration Emergency Declaration. Los Angeles: Right to Counsel San Diego: Broad Limits on Rental Fees.