Background
SVF Grosvenor Del Rey Corporation, a landlord, filed an unlawful detainer action against tenant Lisa Schwarz after she allegedly failed to pay $23,472 in rent (six months at $3,912 per month) for an apartment at 5550 Grosvenor Boulevard in Los Angeles. The landlord served a three-day pay-or-quit notice in June 2024 that listed two payment options.
The first option was payment “by mail to Leasing Office 5550 Grosvenor Blvd Los Angeles, CA 90066” — with no person’s name and no telephone number. The second option was personal delivery to “Barrington Thomas or any available personnel” at the same address, with a phone number and office hours. Schwarz moved for judgment on the pleadings, arguing the mail option was fatally defective because it omitted the name and telephone number of a person to whom rent could be mailed. The trial court agreed and entered judgment for the tenant.
The Court’s Holding
The Appellate Division of the Los Angeles County Superior Court affirmed. The three-day pay-or-quit notice was defective because the mail payment option failed to include the name and telephone number of a person, as required by Code of Civil Procedure section 1161(2).
The court performed a close textual analysis of the statute. Section 1161(2) requires the notice to state “the name, telephone number, and address of the person to whom the rent payment shall be made.” This baseline requirement applies to all payment methods — there is no language restricting it to in-person delivery. The personal delivery clause (“if payment may be made personally, the usual days and hours”) is an additional requirement layered on top, not a substitute.
The court rejected the landlord’s argument that listing a contact name and phone number in the personal delivery option could carry over to satisfy the mail option. A tenant reading only the mail option — which appeared first on the notice — would have no name to address the envelope to and no number to call with questions. Requiring tenants to piece together compliance from multiple sections of the notice would defeat the statute’s purpose of providing clear, immediately usable payment information.
Key Takeaways
- Each payment option listed in a California three-day pay-or-quit eviction notice must independently include the name, telephone number, and address of a specific person — “Leasing Office” alone is not sufficient.
- Strict compliance with Code of Civil Procedure section 1161(2) is required; substantial compliance will not save a defective notice.
- A contact name and phone number listed in a personal delivery option do not carry over to satisfy requirements for a mail payment option elsewhere in the same notice.
- The statutory requirements were added in 2001 specifically to prevent tenant confusion about how and to whom to pay rent, which could otherwise lead to unjust evictions.
Why It Matters
This decision establishes a clear, bright-line rule for California landlords and property managers: every payment option on a three-day pay-or-quit notice must independently list the name, phone number, and address of a specific person. Addressing rent to a “leasing office” or a generic entity is not enough, even if a person’s name appears elsewhere in the notice under a different payment method.
For landlords and their attorneys, the practical lesson is straightforward: review your notice templates now. Many large property management companies use standardized forms where the mail-payment line defaults to the management office rather than a named individual. Under this ruling, that practice renders the entire eviction notice void. For tenant advocates, the case reinforces the strict-compliance standard that protects renters from losing their homes due to notices that do not clearly explain how to cure a default.