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tenants for the purposes of the applicability of TPA protections post the resident manager’s
employment termination, we undertake that task here.
Applicable Law and Standard of Review
The TPA of 2019 (Civ. Code, § 1946.2 et seq.) is a comprehensive anti-rent gouging and
eviction control law. (Borden v. Stiles (2023) 92 Cal.App.5th 337, 346.) It provides, in
relevant part that, “after a tenant has continuously and lawfully occupied a residential real
property for 12 months, the owner of the residential real property shall not terminate a tenancy
without just cause, which shall be stated in the written notice to terminate tenancy. [¶] . . . [¶]
(1) At-fault just cause, . . . means any of the following: [¶] . . . [¶] (J) The employee, agent, or
licensee’s failure to vacate after their termination as an employee, agent, or a licensee as
described in paragraph (1) of Section 1161 of the Code of Civil Procedure.” (Civ. Code, §
1946.2.) “‘Tenancy’ means the lawful occupation of residential real property and includes a
lease or sublease.” (Civ. Code § 1946.2, subd. (k)(3), emphasis added.)
“An owner of residential real property subject to this section shall provide notice to the
tenant as . . . [¶] . . . an addendum to the lease or rental agreement, or as a written notice.” (Civ.
Code § 1946.2, subd. (f).) “The notification or lease provision shall be in no less than 12-point
type, and shall include the following: [¶] ‘California law limits the amount your rent can be
increased. See Section 1947.12 of the Civil Code for more information. California law also
provides that after all of the tenants have continuously and lawfully occupied the property for
12 months or more or at least one of the tenants has continuously and lawfully occupied the
property for 24 months or more, a landlord must provide a statement of cause in any notice to
terminate a tenancy. See Section 1946.2 of the Civil Code for more information.’” (Civ. Code
§ 1946.2, subd. (f)(3).) “An owner’s failure to comply with any provision of this section shall
render the written termination notice void.” (Civ. Code § 1946.2, subd. (g).)
“We review matters of statutory interpretation de novo. [Citation.] ‘Statutory
interpretation requires us “to ascertain and effectuate the intended legislative purpose.”
[Citation.] We consider the provisions’ language in its “broader statutory context” and, where
possible, harmonize that language with related provisions by interpreting them in a consistent
fashion. [Citation.] If an ambiguity remains after this preliminary textual analysis, we may