A recent California Court of Appeal ruling secured by the California Apartment Association is already reshaping litigation over similar tenant relocation requirements elsewhere in the state, including a pending challenge to the City of Los Angeles’s rent-increase relocation mandate.

In late December, the Court of Appeal asked the parties in Apartment Association of Greater Los Angeles County v. City of Los Angeles to submit supplemental briefing addressing how the court’s December decision in California Apartment Association v. City of Pasadena affects the legality of Los Angeles’ ordinance. The Pasadena ruling 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 signals that the CAA decision is now being treated as pivotal on the core legal question in the Los Angeles case: whether cities may impose financial penalties tied to rent increases on units that state law expressly exempt 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 CAA ruling compels the same outcome in Los Angeles. Housing providers argue the ordinances are materially indistinguishable and that the court’s reasoning applies with equal force. The city and tenant advocates contend the laws can be distinguished, but the appellate court’s decision to request briefing underscores the growing reach of the CAA victory beyond Pasadena.

The development comes just weeks after the CAA ruling in Pasadena was issued. That decision marked a significant win for CAA, 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.

Whitney Prout

“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 CAA ruling highlights its potential to curb the spread of relocation assistance mandates tied to lawful rent increases statewide.