CA Court Ruling Threatens Three-Day Eviction Notices

California Supreme Court May Depublish Confusing “Three-Day Notice” Ruling

On July 21, 2025, the California Apartment Association (CAA) formally asked the California Supreme Court to depublish a recent appellate decision that created ambiguity around the content required for landlord-issued “three-day notices to pay or quit.” If granted, this would remove the case—Eshagian v. Cepeda—from being cited as legal precedent, even though it remains binding between the involved parties.

What the Appellate Court Decision Said (Eshagian v. Cepeda)

On June 26, 2025, the California Court of Appeal held that a three-day notice was legally insufficient because it failed to specify crucial timing details—namely:

• When the notice period began and ended 
• The notice’s service date 

The court emphasized that an “ordinary tenant” must clearly understand when the three-day countdown starts. Failure to meet this standard can invalidate eviction proceedings—even when other legal requirements are met.

 Why This Ruling Matters for Landlords

1. Risk of Eviction Delays
   A faulty three-day notice could lead to dismissal of eviction cases, prolonging unlawful detainers and increasing legal fees. 
2. Expanded Notice Requirements
   All three-day notices—including those for lease violations—may now require clear service and deadline language to survive legal scrutiny. 
3. Need for Legal Review
   Self-drafted notices should be reviewed by attorneys to ensure compliance with the court’s interpretation of notice rules. 

Recommended Actions for Rental Property Owners

• Consult legal counsel to revise three-day notice templates and include: 
  • Clear service date 
  • Beginning and end dates for the three-day period 
  • Exclusions for weekends and judicial holidays 
• Pause eviction proceedings if notices were served using forms based on the old standard. 
• Stay updated on the Supreme Court’s decision regarding depublication, which could reshape notice practices. 

Legal Tip

Because California’s unlawful detainer laws are strict, even small omissions in notice language can derail eviction efforts. Having correctly drafted forms and legal advice is crucial to preserve your rights.

Partner with Real Property Management Select

At Real Property Management Select, we stay ahead of California’s rapidly changing landlord-tenant laws. From notice templates to court documentation, our team ensures your rental business remains compliant—every step of the way.

Our eviction rate remains below 1% — a testament to our thorough screening process, respectful tenant relationships, and proactive management approach. By addressing issues early, working closely with tenants, and selecting residents carefully, we help property owners maintain stable, long-term occupancy and avoid unnecessary legal risks.

Whether you manage a single-family home or an entire portfolio, we help you stay protected and profitable with reliable processes that work—even when laws shift.