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
Original Source: https://www.courtlistener.com/opinion/7861646/2710-sutter-ventures-llc-v-millis/ ↗

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relatedly, what standard applies to assess such compliance.
Defendants argue that plaintiffs did not strictly comply with the
notice provision as required by the Rent Ordinance and unlawful
detainer jurisprudence (e.g., Kwok v. Bergren (1982)
130 Cal.App.3d 596, 599–600). Plaintiffs initially argued that
Government Code section 7060.6 provides the applicable
standard, and that section 7060.6 mandates a straightforward
“mere compliance” standard by abrogating the strict compliance
standard used in unlawful detainer actions.9 In their
supplemental brief, however, plaintiffs claim that the doctrine of
substantial compliance applies.10 As set forth below, we conclude
that, regardless of whether the strict compliance standard
applies to the notice at issue, the trial court correctly found a lack
of compliance.
      Courts have applied the doctrine of substantial compliance
with statutory requirements when, as a practical matter, they
can reasonably conclude that partial compliance with a law has
fully attained the statute’s objectives. (3 Sutherland, Statutory
Construction (8th ed. 2021) § 57:26.) “ ‘ “Substantial compliance,
as the phrase is used in the decisions, means actual compliance

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