A recent California Court of Appeal ruling has changed what landlords and property managers must include in their Three-Day Notices to Pay Rent or Quit. If you own or manage rental property in California, this update is critical to ensure your notices remain legally enforceable.
The Case: Eshagian v. Cepeda
On June 26, 2025, the California Court of Appeal (Second District) issued its decision in Eshagian v. Cepeda. The court found that a Three-Day Notice is deficient if it does not clearly state the start and end dates of the three-day compliance period.
In other words, tenants must be told exactly when their three days begin and when they expire. Without that clarity, a notice may be ruled invalid in court and an eviction action could be dismissed.
What This Means for Landlords
Under the new interpretation, a valid Three-Day Notice to Pay Rent or Quit must include:
- The specific start date and end date of the three-day notice period.
- A clear demand for the exact amount of rent due.
- Instructions on who to pay (name, address, phone number) and the hours or method for making payment.
Notices that omit these details may no longer support an eviction case in California.
Industry Response
Following the ruling, the California Apartment Association (CAA) advised members to pause the use of existing Three-Day Notices and 30-Day CARES Act notices until compliant forms could be released.
On July 10, 2025, CAA published updated versions of these notices that include the required date fields and other court-mandated language. These updated forms are now available to landlords and property managers.
Next Steps for Property Owners
If you are serving a Three-Day Notice:
- Stop using old forms immediately.
- Download the updated CAA notices (if you’re a member) or review your own forms to ensure compliance.
- Consult your attorney before serving notices to confirm you’re meeting the new legal requirements.
Final Thoughts
The Eshagian v. Cepeda ruling is a reminder that landlord-tenant law continues to evolve in California. Staying current with these changes protects both your property interests and your ability to enforce lease agreements.
At Maher Commercial Realty, we’re committed to keeping our clients informed on the latest developments in real estate law. If you have questions about how this ruling may affect your rental operations, please reach out to our team.
