Updated versions of the California Apartment Association’s three-day notices and 30-day CARES Act notices are now available for download from the association’s website. Revised fillable online forms are also now available for online forms tool subscribers.

These updates were made in response to the June 26, 2025, decision by the California Court of Appeal in Eshagian v. Cepeda. In that case, the court invalidated a non-CAA three-day notice because it lacked sufficient information for the tenant to determine what the notice required them to do and by when. Specifically, the court cited the absence of details such as the start and end dates of the notice period and the date the notice was served, even though such details have not historically been required.

While CAA’s prior forms arguably remained compliant with the law because they inform tenants that the notice period begins upon service, the association has revised them out of an abundance of caution to address the questions raised by the Eshagian ruling and to help its members avoid potential legal challenges.

For background on the Eshagian v. Cepeda decision and CAA’s initial recommendations, see last week’s article: New court decision impacts three-day notices – member action needed.

Updated forms include:

Statewide three-day notices

CARES Act notices

Local notices