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DRAFT FOR ATTORNEY REVIEW — NOT FINAL

2710 Sutter Ventures, LLC v. Millis (2022)

Citation
2710 Sutter Ventures, LLC v. Millis (2022)
Parent Document
2710 Sutter Ventures, LLC v. Millis (2022)
Jurisdiction
California (state)
Effective Date
2022-08-31

Other Sections in This Document (66)

Full Text

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16
displacement.” (Coyne, supra, 9 Cal.App.5th at p. 1227.) The
Rent Ordinance’s requirement that landlords pay reasonable
relocation assistance benefits is a “valid and appropriate
exercise[] of a public entity’s power to mitigate adverse impacts
on displaced tenants under section 7060.1, subdivision (c).”
(Coyne, at p. 1228; see also Pieri v. City and County of San
Francisco, supra, 137 Cal.App.4th at pp. 893–894 (Pieri);
Johnson, supra, 137 Cal.App.4th at p. 16, fn. 7 [“[S]ection 7060.1,
subdivision (c), specifically addresses the permissibility of
relocation assistance, providing that nothing in the Ellis Act
‘[d]iminishes or enhances any power in any public entity to
mitigate any adverse impact on persons displaced by reason of
the withdrawal from rent or lease of any accommodations’ ”].)
Unlike the belief requirement at issue in Johnson, and as
Johnson itself appears to have recognized (Johnson, at pp. 16,
fn. 7, 18), notice to tenants of the right to relocation payments
validly serves to mitigate the adverse impacts on displaced
persons under Government Code section 7060.1, subdivision (c).
(See id. at § 7060.7, subd. (c) [the Act does not override
procedural protections designed to prevent abuse of right to evict
tenants].)
      Nor does section 37.9A(e)(4)’s notice requirement create an
undue burden. “Any notice to quit pursuant to Section
37.9(a)(13) shall notify the tenant or tenants concerned of the
right to receive [relocation assistance] payment . . . .”
(§ 37.9A(e)(4).) The notice required is to “tenant” or “tenants.”
As Danger Panda explained, “tenant” as used in section 37.9A,