New Case Clarifies Civil Code § 1962 Compliance Is Not Part of Landlord’s Prima Facie Case

In 360 So. Reeves, LLC v. Dutton (App. Div. L.A. Sup. Ct., Feb. 27, 2026), the Appellate Division of the Los Angeles Superior Court clarified that compliance with Civil Code section 1962 is not an element of a landlord’s prima facie case in an unlawful detainer action for nonpayment of rent. Instead, the issue arises only if specifically raised and proven by the defendant. The decision also disapproved prior language suggesting section 1962 compliance is a jurisdictional prerequisite.

A “prima facie case” refers to the basic elements a landlord must prove to obtain judgment unless the tenant establishes a valid defense. By confirming that Civil Code section 1962 compliance is not part of that initial showing, the decision narrows what landlords must affirmatively establish at trial.

Civil Code section 1962 generally requires landlords and successor owners or managers to provide written contact information identifying where rent payments should be made and who is authorized to receive notices and service of process. The information must be kept current, and successor owners or managers must provide updated disclosures after a change in ownership or management.

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The law firm of Wallace, Richardson, Sontag & Le, LLP represents landlords, property management companies, institutional and private lenders, employers and insurance companies throughout the State of California in real estate, business and employment litigation. The information provided herein is for general interest only and should not be relied upon or construed as legal advice.