The California Court of Appeal on Thursday ruled in favor of the California Apartment Association on key state law issues in its appeal challenging Pasadena’s rent control law, Measure H.

In its ruling, the court agreed with CAA that certain provisions of Measure H are preempted by state housing law. Specifically, the court concluded that Pasadena may not require relocation assistance payments tied to rent increases on units exempt from local rent control, and that the city may not impose additional notice requirements that modify the eviction process established under state statute.

The appeal arises from CAA’s lawsuit challenging Measure H, a voter-approved measure adopted by Pasadena in 2022. The association raised constitutional and statutory claims related to the structure of the city’s rent board, the manner in which Measure H was adopted, and whether specific provisions of the law conflict with state housing statutes.

Preemption issues

With respect to state law preemption, the court agreed with CAA that Pasadena’s relocation assistance requirement conflicts with state housing law, including the Costa-Hawkins Rental Housing Act, which limits the types of rent control cities may impose and exempts certain properties from local rent regulation, and the Tenant Protection Act, the statewide rent cap and eviction law adopted in 2019 as AB1482. CAA argued that state law allows housing providers to set rents on exempt units and does not authorize cities to require relocation payments when tenants move following a lawful rent increase.

The court also agreed with CAA that Pasadena’s requirement for a preliminary “notice to cease” before serving a standard three-day notice improperly alters eviction procedures governed by state law.

Other claims

The court rejected CAA’s arguments that Measure H constituted an improper revision of Pasadena’s city charter and that the composition of the rent board violated constitutional principles. Those claims addressed the structure and governance of the rent board rather than the application of specific provisions of the law.

“While CAA is disappointed that the Court of Appeal did not overturn the trial court’s decision in its entirety, the ruling reaffirms the importance of state-level protections such as the Costa-Hawkins Rental Housing Act and California’s eviction procedures,” said Joshua Howard, CAA’s executive vice president of local public affairs. “The decision confirms that local governments must operate within the limits set by state law.”