Pasadena Rent Control Court Ruling December 2025: What Changed for Landlords
On December 18, 2025, the California Court of Appeal ruled in California Apartment Association v. City of Pasadena, striking down two key provisions of Measure H. The court invalidated Pasadena's requirement that single-family and condo landlords pay relocation assistance when tenants move out after rent increases. It also struck down the "notice to cease" requirement for non-payment evictions. Core Measure H provisions including rent caps for covered properties, the rental registry, and just-cause eviction protections remain fully intact.
What Just Happened: The Ruling Explained
The California Apartment Association (CAA) challenged Pasadena's Measure H shortly after it passed in November 2022, arguing that portions of the ordinance conflicted with state law, specifically the Costa-Hawkins Rental Housing Act and the Unlawful Detainer Act.
After working through the court system and oral arguments in September 2025, the California Court of Appeal, Second Appellate District, Division Seven issued its decision on December 18, 2025. The ruling was a partial victory for landlords, but not the wholesale invalidation some had hoped for.
As the CAA stated: "The decision confirms that local governments must operate within the limits set by state law."
What the Court Struck Down
1. Relocation Assistance for Rent-Increase-Driven Move-Outs (SFRs and Condos)
The original Measure H rule: If a single-family home or condo landlord raised rent more than 5%, and the tenant moved out within 6 months of that increase, the landlord had to pay relocation assistance, even though the tenant left voluntarily.
The court's reasoning: Costa-Hawkins specifically exempts single-family homes and condominiums from local rent caps. By requiring relocation payments triggered by rent increases, Pasadena was effectively penalizing landlords for raising rent, which functions as a de facto rent cap on exempt properties.
The ruling: This provision is preempted by Costa-Hawkins and declared void for single-family homes and condominiums.
If you own a single-family home or condo in Pasadena, you can now raise rent to market rate without triggering automatic relocation obligations when tenants leave voluntarily. The fear of a $7,000-$20,000+ relocation bill for exercising your Costa-Hawkins rights is eliminated.
2. Additional Notice Requirements for Non-Payment Evictions
The original Measure H rule: Pasadena required landlords to provide a preliminary "notice to cease" beyond what state law requires before proceeding with eviction for non-payment of rent.
The court's reasoning: California has a comprehensive statutory scheme for evictions under the Unlawful Detainer Act. Local ordinances that add procedural requirements conflict with state law and create confusion about which rules apply.
The ruling: Pasadena's extra notice requirements for non-payment evictions are preempted by state law.
What this means for you: If you need to evict for non-payment, you follow standard state law procedures, not additional Pasadena-specific steps. This simplifies the process and reduces the risk of procedural errors that could delay eviction.
Need help understanding how this affects your property? I can walk you through the specifics.
📞 (213) 444-2225What the Court Left in Place
The ruling was narrowly focused. Most of Measure H remains fully enforceable:
Rent Caps for Covered Properties: STILL IN EFFECT
Multifamily properties built before February 1, 1995 are still subject to the Annual General Adjustment (2.25% for 2025-2026). This did not change.
Just-Cause Eviction Protections: STILL IN EFFECT
All Pasadena tenants (including those in single-family homes and condos) still have just-cause eviction protection after 12 months of tenancy. You still need a qualifying reason to evict.
Rental Registration Requirement: STILL IN EFFECT
All rental properties must still register with the Rental Housing Board annually. The $238/unit fee still applies.
Relocation Assistance for No-Fault Evictions: STILL IN EFFECT
If you formally evict a tenant through owner move-in, Ellis Act, demolition, or substantial rehabilitation, you still owe relocation assistance. The court only struck down relocation for voluntary move-outs after rent increases on exempt properties.
Tenant-Majority Rent Board: STILL IN EFFECT
The 7-4 tenant-majority board structure was challenged but upheld by the court. The board retains authority over registration, compliance, and disputes.
Before and After: What Changed for Each Property Type
Single-Family Homes and Condos
| Issue | Before Ruling | After Ruling |
|---|---|---|
| Rent caps | Exempt (Costa-Hawkins) | Exempt (no change) |
| Relocation for >5% increase + move-out | Required | NOT required |
| Relocation for formal no-fault eviction | Required | Required (no change) |
| Just-cause eviction | Required | Required (no change) |
| Registration | Required | Required (no change) |
| "Notice to cease" before 3-day notice | Required | NOT required |
Multifamily Properties (Pre-1995)
| Issue | Before Ruling | After Ruling |
|---|---|---|
| Rent caps (2.25% AGA) | Required | Required (no change) |
| Relocation for formal no-fault eviction | Required | Required (no change) |
| Just-cause eviction | Required | Required (no change) |
| Registration | Required | Required (no change) |
| "Notice to cease" before 3-day notice | Required | NOT required |
Considering your options after this ruling? Let's discuss what makes sense for your situation.
📱 (213) 444-2225Timeline: How We Got Here
The city could potentially appeal to the California Supreme Court, but as of now, the appellate ruling stands and is in effect.
Practical Implications for Pasadena Landlords
If You Own a Single-Family Home or Condo
Before the ruling: Many landlords avoided raising rent to market rate because a tenant move-out could trigger $7,000-$20,000+ in relocation costs. The financial risk of exercising Costa-Hawkins rights often exceeded the benefit.
After the ruling: You can now raise rent without that specific penalty. If market rent is $4,500 and you're charging $3,200, you can issue a proper rent increase without automatic relocation exposure for voluntary move-outs.
What you still need to do:
- Provide proper notice (30 days for ≤10% increase, 90 days for >10%)
- Remain registered with the Rental Housing Board
- Comply with just-cause eviction rules if you want to terminate tenancy
- Pay relocation if you pursue formal no-fault eviction
If You Own a Multifamily Building (Pre-1995)
The ruling changes little for you. Your property is still subject to rent caps, and the relocation provisions weren't the issue for rent-controlled properties since you can't raise rent above the AGA anyway.
The main practical change is the simplified eviction notice procedure for non-payment, following standard state law rather than Pasadena-specific requirements.
If You're Considering Selling
The ruling may slightly increase the value of single-family rental homes and condos by removing one compliance burden. However, just-cause eviction protections remain, which still affects how buyers evaluate occupied properties.
What the Ruling Does NOT Mean
It does NOT mean rent control is gone. Measure H's core rent control provisions for pre-1995 multifamily remain fully intact. The 2.25% cap is unchanged.
It does NOT mean you can evict without cause. Just-cause eviction applies to all Pasadena rental properties regardless of this ruling. You still need a qualifying reason after 12 months of tenancy.
It does NOT mean registration is optional. Every rental property still must register. Failure to register still strips your rights as a landlord.
It does NOT mean no relocation ever. Formal no-fault evictions (owner move-in, Ellis Act, etc.) still require full relocation assistance for all property types.
Understanding Your Options After This Ruling
This ruling creates new possibilities for some landlords, particularly SFR and condo owners. But the interaction between the ruling, Costa-Hawkins, and remaining Measure H requirements can be confusing.
Free consultation on your specific property
Frequently Asked Questions
What did the Pasadena rent control court ruling change?
The December 18, 2025 ruling struck down two Measure H provisions: (1) relocation assistance requirements when single-family/condo tenants move out after rent increases, and (2) the "notice to cease" requirement before serving a standard three-day eviction notice. Core rent control provisions remain intact.
Is Pasadena rent control still in effect after the court ruling?
Yes. Rent caps for pre-1995 multifamily (2.25% AGA), just-cause eviction for all properties, registration requirements, and relocation for formal no-fault evictions all remain in effect. The ruling was narrowly focused.
Can I raise rent on my Pasadena single-family home now?
Yes, and if your tenant moves out voluntarily after the increase, you no longer owe relocation assistance. This was the key change for SFR and condo landlords. You must still provide proper notice and remain registered.
Do I still need to register my rental property in Pasadena?
Yes. The registration requirement was not affected by the ruling. All rental properties must register annually and pay the $238/unit fee by October 31st.
Does just-cause eviction still apply in Pasadena?
Yes. Just-cause eviction protections were not challenged in this lawsuit and remain fully in effect for all rental properties after 12 months of tenancy.
What happens if I do an owner move-in eviction?
You still owe full relocation assistance. The ruling only eliminated relocation for voluntary move-outs after rent increases on exempt properties, not for formal no-fault evictions like owner move-in, Ellis Act, or demolition.
What was the "notice to cease" requirement that was struck down?
Pasadena required landlords to provide additional preliminary notices beyond state law requirements before proceeding with non-payment evictions. The court found this conflicted with the Unlawful Detainer Act, so now landlords follow standard state eviction procedures.
Could Pasadena appeal this ruling?
The city could potentially appeal to the California Supreme Court, but as of now, the appellate ruling stands and is in effect. Most landlords are proceeding based on current law.
