Strict Compliance With Three-Day Pay Rent Or Quit Notice In Unlawful Detainer Action Required.

In an unlawful detainer action, the defendant argued the three-day notice to pay rent or quit was defective because it gave a web address, but not a physical address where the rent should be paid. The trial court determined Code of Civil Procedure section 1161(2) did not specifically require a physical address to be listed and entered judgment for the landlord. The appellate court stated that a valid three day pay rent or quit notice is a prerequisite to an unlawful detainer action, and that “because of the summary nature of an unlawful detainer action, a notice is valid only if the lessor strictly complies with the statutorily mandated notice requirements.” The appeals court concluded the instant notice was insufficient under the statute and reversed. (Foster v. Williams (Cal. App. Sup. Ct., L.A. County; September 9, 2014) 229 Cal.App.4th Supp. 9, [177 Cal.Rptr.3d 371].)