California Landlord in 2026: The Rules Chinese Landlords Keep Getting Wrong

A 2025 Court of Appeal decision just vacated an eviction over a defective 3-day notice. Balcony inspection fines are now accruing daily. New stove, refrigerator, and deposit-refund rules took effect January 1. If you own rental property in California, your 2023 playbook is expired.

The case every landlord should read: Eshagian v. Cepeda

On June 26, 2025, the California Court of Appeal (112 Cal.App.5th 433) vacated a default eviction judgment — not because the tenant had a defense, but because the landlord's 3-day notice to pay or quit was defective. The notice failed to (1) clearly warn the tenant of losing possession, (2) state exactly when the compliance period starts and ends (excluding weekends and court holidays), and (3) name a clear place, payee, and hours for receiving payment.

The lesson is blunt: old notice templates are now hazardous. And the timeline got longer — since January 1, 2025 (AB 2347), tenants have 10 court days (up from 5) to answer an unlawful detainer summons. Fewer default judgments, longer cases, more technical litigation. One eviction attorney's one-year assessment: cases are "more technical, not simpler."

The classic dismissal traps haven't changed: defective service, accepting rent after serving the notice (which waives it), counting weekends in the 3-day period, overstating the rent due, and self-help lockouts. Each one can kill months of work.

AB 1482: know whether you're covered — and the exemption trap

California's Tenant Protection Act (AB 1482) caps annual rent increases at 5% plus CPI, max 10%, imposes just-cause eviction protections after 12 months of tenancy, and requires one month's rent in relocation assistance for no-fault evictions. It sunsets January 1, 2030.

Many Chinese landlords assume they're exempt — and many are wrong about why. The current exemptions:

1. Single-family home or condo owned by a natural person — the owner cannot be a corporation, an LLC with any corporate member, or a REIT. Trusts, partnerships, and all-natural-person LLCs do qualify. But you must give the tenant the written exemption notice — without it, the exemption generally fails. This paperwork step is the single most common exemption killer.
2. Owner-occupied duplex (you live in the other unit).
3. Certificate of occupancy issued within the last 15 years (a rolling window — now meaning buildings built after about 2011).

Ignore older guides claiming a "10 or fewer single-family properties" test — that was never the rule. And note: even exempt properties in Los Angeles City still face the city's own rent stabilization and just-cause ordinances.

The 2025–2026 rule changes you may have missed

Several new laws are already biting:

• Security deposits: one month, period (AB 12, since July 2024). One month's rent whether furnished or not. The only exception: a natural-person landlord with no more than two properties totaling four or fewer units may collect two months — never from a service member.
• Photograph everything (AB 2801). For tenancies starting on or after July 1, 2025, move-in photos are required; for tenancies ending on or after April 1, 2025, post-move-out photos must be taken before repairs. Skip this and you jeopardize your right to keep any deposit deductions.
• Deposit refunds went electronic (AB 414, effective January 1, 2026). If rent or deposit was paid electronically, the refund must be electronic unless otherwise agreed in writing. For multiple adult tenants, the refund check must be payable to all of them.
• Stoves and refrigerators are now habitability items (AB 628, effective January 1, 2026). New, renewed, or amended leases must include a working stove and refrigerator as part of the "tenantable" standard — and you maintain them.