Cal. Apartment Assn. v. City of Pasadena (2025)

Citation: Cal. Apartment Assn. v. City of Pasadena (2025)
Parent Document: Cal. Apartment Assn. v. City of Pasadena (2025)
Jurisdiction: California (state)
Effective Date: 2025-12-18
Original Source: https://www.courtlistener.com/opinion/10761039/cal-apartment-assn-v-city-of-pasadena/ ↗

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and enforce particular local laws governing landlord-tenant
relations, including those related to evictions and rent control.”
(Italics added; accord, NCR Properties, supra, 89 Cal.App.5th at
p. 56 [“Local governments may make and enforce rent control
‘ordinances and regulations not in conflict with’ state law.”].)
Field preemption thus does not apply to the relocation assistance
requirement.
              c.    The relocation assistant requirement
                    contradicts the Costa-Hawkins Act
        The closer question is whether the requirement under
section 1806(b)(C) that landlords pay relocation assistance to
tenants who are unable to pay increased rent—that the Costa-
Hawkins Act authorizes landlords to charge—contradicts the Act
and is thus preempted.
        The superior court found there was no such contradiction.
The court explained that section 1806(b)(C) does not restrict the
ability of a landlord to increase the rent for an exempt unit to the
maximum allowed under state law. The court acknowledged that
“[i]f tenants leave because they are unable to pay that amount,
section 1806(b)(C) may result in the rent increase becoming less
lucrative, in some cases, due to the payment of relocation
assistance.” Because the Rental Board had not yet set the
amount of the relocation assistance payments, however, the court
concluded it could not assess on a purely facial challenge
petitioners’ contention that relocation assistance could “cancel
out or substantially reduce any rent increase.”
        We disagree with the superior court’s determination that
petitioners’ argument may not be assessed in a facial challenge as
well as the court’s conclusion that there is no conflict between

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