Dr. Leevil, LLC v. Westlake Health Care Center

At issue was the timing of the notice that must precede an unlawful detainer action where the action is not brought by a landlord but by a new owner who has acquired title to the property under a power of sale contained in a deed of trust. The Supreme Court held that perfection of title, which includes recording the trustee’s deed, is necessary before the new owner serves a three-day written notice to quit on the possessor of the property. The Court thus reversed the judgment of the Court of Appeal concluding that perfection of title need only precede the filing of the unlawful detainer action and that the new owner may serve the notice to quit immediately after acquiring ownership. View "Dr. Leevil, LLC v. Westlake Health Care Center" on Justia Law