A recent California Court of Appeals decision centered on Pasadena’s rent-increase relocation rules is now shaping a separate legal battle over a similar ordinance in Los Angeles, after the appellate court asked parties to explain how the Pasadena ruling affects the Los Angeles case. The ruling was secured by the California Apartment Association and is already reshaping litigation over similar tenant-relocation requirements elsewhere in the state, including the pending challenge to Los Angeles’ rent-increase relocation mandate.
In late December, the Court of Appeal directed the parties in Apartment Association of Greater Los Angeles County v. City of Los Angeles to submit supplemental briefing on the impact of its December opinion in California Apartment Association v. City of Pasadena. The Pasadena decision held that a local requirement forcing housing providers to pay relocation assistance in response to lawful rent increases on units exempt from local rent control under Costa-Hawkins is preempted by state law.
The court’s request signaled that the Pasadena ruling is now central to determining whether cities may impose financial penalties tied to rent increases on units that state law exempts from local rent regulation. Los Angeles’ ordinance, like Pasadena’s Measure H, requires relocation payments when a tenant moves out after a rent increase exceeding a specified threshold.
In their supplemental filings, the parties sparred over whether the Pasadena ruling compels the same outcome in Los Angeles. Housing providers argued the two ordinances are materially indistinguishable and that the court’s reasoning applies equally. The city and tenant advocates contended the laws can be distinguished, but the appellate court’s decision to request briefing underscored the growing reach of the CAA victory beyond Pasadena.
The development came just weeks after the CAA ruling in Pasadena was issued. That decision marked a significant win for the California Apartment Association, with the court agreeing that Pasadena’s rent-increase relocation-assistance requirement conflicted with the Costa-Hawkins Rental Housing Act — a law CAA sponsored in the 1990s — by penalizing lawful rent increases on exempt units, and that the city’s additional non-payment-of-rent eviction-notice requirements were likewise preempted by state law.
Separately, intervenors in the Pasadena case sought rehearing, arguing that the court relied on legal theories they had not been given a fair opportunity to brief. The Court of Appeal promptly rejected that request earlier this month, leaving its December opinion intact and clearing the way for the ruling to be cited in other cases.
“CAA’s victory in Pasadena is already influencing how courts evaluate similar ordinances,” said Whitney Prout, CAA’s executive vice president of legal affairs. “The ruling reinforces that cities must operate within the boundaries set by state housing law.”
The Los Angeles appeal remains pending, but the court’s focus on the Pasadena ruling highlights its potential to curb the spread of relocation-assistance mandates tied to lawful rent increases statewide.
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