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DRAFT FOR ATTORNEY REVIEW — NOT FINAL

Rich v. Schwab, 75 Cal. Rptr. 2d 170 (1998)

Citation
Rich v. Schwab, 75 Cal. Rptr. 2d 170 (1998)
Parent Document
Rich v. Schwab, 75 Cal. Rptr. 2d 170 (1998)
Jurisdiction
California (state)
Effective Date
1998-06-01

Other Sections in This Document (60)

Full Text

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In Aweeka v. Bonds (1971) 20 Cal.App.3d 278, 281, 97 Cal.Rptr. 650 (Aweeka), the court held that not only may a tenant use retaliation as a defense to an unlawful detainer action, a tenant may also allege an affirmative cause of action for retaliatory eviction. In Aweeka the tenants gave notice to the landlord that unless repairs to their apartment were made, they would deduct the cost of the repairs from their rent. In response the landlord almost doubled their rent. After they were unsuccessful in obtaining an injunction against enforcement of the rent increase, the tenants voluntarily vacated the premises. In finding that a common law cause of action for retaliatory eviction existed on these facts, the court stated: "We can discern no rational basis for allowing such a substantive defense while denying an affirmative cause of action. It would be unfair and unreasonable to require a tenant, subjected to a retaliatory rent increase by the landlord, to wait and raise the matter as a defense only, after he is confronted with an unlawful detainer action and a possible hen on his personal property." (Id. at p. 281, 97 Cal.Rptr. 650; see also Glaser v. Meyers (1982) 137 Cal.App.3d 770, 776, 187 Cal.Rptr. 242 (Glaser).)