At a Glance
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The California Apartment Association (CAA) has filed a supplemental brief in its ongoing appeal over Pasadena’s voter-approved rent control law, Measure H.
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The filing challenges portions of Measure H, including relocation-assistance requirements, arguing that they conflict with state housing laws, such as Costa-Hawkins.
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Pasadena and tenant advocates defend the measure as a local safeguard against displacement.
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The Court of Appeal requested additional arguments following the oral hearings, signaling the issue’s statewide importance.
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A ruling in this case could reshape how local rent control interacts with state law throughout California.
Background: Measure H and the Legal Challenge
In 2022, Pasadena voters approved Measure H, establishing rent stabilization, eviction protections, and the creation of the Pasadena Rental Housing Board to oversee enforcement. The measure also requires relocation payments for tenants who move out after significant rent increases or other qualifying circumstances.
Shortly after its passage, the California Apartment Association filed a lawsuit claiming Measure H violates state law and exceeds the city’s charter authority. In 2023, Los Angeles Superior Court Judge Mary Strobel largely upheld the ordinance, siding with the city on most counts while striking down limited sections related to extended eviction-notice timelines.
Unconvinced, the CAA appealed the decision to the California Court of Appeals. After oral arguments, the appellate panel requested supplemental briefing — a rare move that often signals complex questions remain unresolved.
CAA’s Core Arguments
In its new filing, the CAA reiterates its claim that Pasadena’s rent control law overreaches local authority.
Key points include:
1. Conflict with State Law
CAA argues that Pasadena’s relocation-payment requirements penalize landlords for actions explicitly allowed under state law, such as raising rents or terminating tenancies under legal conditions.
“The relocation payment requirement effectively punishes property owners for doing something that state law expressly allows,” the brief states. “It has no logical connection to legitimate local authority over evictions.”
2. Costa-Hawkins Protections
Under the Costa-Hawkins Rental Housing Act, certain properties, such as single-family homes and newer apartments, are exempt from local rent control. CAA contends Pasadena’s ordinance undermines those exemptions by forcing relocation payments even when state law protects landlords from local rent caps.
3. Defining an “Eviction”
CAA asserts that a tenant leaving after a lawful rent increase is not an eviction. Therefore, requiring relocation fees in such cases exceeds local authority and conflicts with state definitions.
4. Limits of AB 1482
The Tenant Protection Act (AB 1482) establishes statewide limits on rent increases and just-cause evictions. Still, CAA states that it does not grant cities broader powers to impose new financial obligations on landlords.
Pasadena’s and Tenant Advocates’ Response
Pasadena and tenant representatives strongly disagree, arguing that the CAA’s interpretation is too narrow.
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Local Authority: The city maintains it has broad powers to address housing stability and mitigate displacement — the relocation requirement is a mitigation tool, not a penalty.
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Constructive Eviction: Tenant groups argue that sharp rent hikes effectively force tenants out, which is no different than an eviction in practice.
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Balancing Rights: Supporters insist that Measure H strikes a fair balance between landlord rights and the community’s interest in maintaining affordable housing.
Why It Matters
This appeal could influence rent control and tenant-protection policy across California.
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A CAA victory could limit the ability of local governments to impose relocation-payment or “move-out” requirements — especially for properties exempt under state law.
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A Pasadena victory would affirm cities’ rights to tailor local solutions to housing affordability and displacement, even within the boundaries of state frameworks.
Either outcome could reshape how municipalities statewide craft — or defend — their housing ordinances.
What’s Next
With supplemental briefs now submitted, the case is under review by the California Court of Appeals. A decision is expected in the coming months.
Stakeholders across the state — from housing advocates to property owners — are closely watching the outcome. The court’s ruling could serve as a blueprint for balancing local innovation with state authority in future rent stabilization efforts.
PFAR Perspective
For REALTORS®, this case underscores how policy decisions ripple through the housing ecosystem — from investment strategies to tenant relations. Whether the court sides with the CAA or the City of Pasadena, the ruling will likely influence future legislation, rental trends, and the evolving definition of “local control” in California housing. PFAR continues to monitor legislative and legal developments that affect REALTORS®, and homeowners across the region.
