How Measure H Came to Exist — and Who It Affected

Pasadena is a dense, high-cost rental market. Its housing stock is old: a substantial share of the city's multifamily rental units were built before 1995, the year California's Costa-Hawkins Rental Housing Act drew a line exempting newer construction from local rent control. For the roughly 24,852 units in Pasadena's pre-1995 multifamily housing stock, the conditions for a rent stabilization fight had been building for years.¹

In November 2022, a coalition of tenant advocates placed Measure H on the Pasadena ballot as a city charter amendment. The measure passed with 52.8 percent of the vote and took effect in December 2022. It was one of the most comprehensive local rent control measures in the Los Angeles area — rolling back rents to May 2021 levels for existing tenants, capping future annual increases at 75 percent of the Consumer Price Index, establishing an independent Rental Housing Board with a tenant supermajority, and prohibiting evictions without just cause for both pre-1995 and post-1995 multifamily units.²

Within days of Measure H's certification, the California Apartment Association and five individual Pasadena landlords filed suit in Los Angeles Superior Court challenging its validity on multiple grounds. That lawsuit — Case No. 22STCP04376, later Case No. B329883 on appeal — would work its way through two levels of California courts over the next three years, producing a December 2025 ruling that reshaped how local rent control interacts with state housing law across Southern California.

The Two Provisions That Were Struck Down — and Why

The Court of Appeal's ruling was not a wholesale rejection of Measure H. Most of the ordinance survived intact. What the court struck down were two specific provisions that it found in direct conflict with California state law — and the reasoning behind each decision is important for any landlord or property manager in the Los Angeles area.

Struck Down #1: Relocation Assistance Tied to Rent Increases

Measure H required landlords to pay relocation assistance to tenants who moved out following a rent increase above five percent — even when that rent increase was entirely lawful and even on units that are exempt from rent control under Costa-Hawkins, such as single-family homes and condominiums.³

The California Apartment Association argued that this was a backdoor form of rent control: if a landlord faces a financial penalty every time a tenant leaves after a lawful rent increase, the practical effect is to discourage the landlord from raising rent at all — on units the state has explicitly exempted from local rent regulation. The Costa-Hawkins Rental Housing Act, enacted in 1995, gives landlords the right to set rents freely on exempt units and to raise them to market rate upon vacancy. Pasadena's relocation requirement, the CAA argued, conflicted directly with those rights.⁴

The Court of Appeal agreed. It held that Pasadena could not require landlords to pay relocation assistance when tenants voluntarily depart following a lawful rent increase on a Costa-Hawkins-exempt unit. The provision was preempted by state law and therefore void.²

Struck Down #2: The "Notice to Cease" Pre-Eviction Requirement

Measure H required landlords to serve tenants with a preliminary "notice to cease" before serving a standard three-day notice to pay rent or quit in a non-payment eviction. This added an extra procedural step that does not exist in California's Unlawful Detainer Act — the state statute that governs the eviction process.³

The court found that Pasadena's extra notice requirement conflicted with state eviction procedures and was preempted. Landlords in Pasadena now follow the standard state eviction process for non-payment cases — serve the required notice, wait the statutory period, and file for unlawful detainer if the tenant does not comply — without the additional preliminary step Measure H had imposed.

What Measure H Provisions Survived — The Full Scorecard

The Legal Framework Behind the Ruling

To understand why the court ruled as it did, it helps to understand how state and local housing law interact in California — and where Costa-Hawkins draws the line.

What Pasadena-Area Landlords Need to Do Now

The December 2025 ruling left most of Measure H intact. Landlords who own pre-1995 multifamily rental units in Pasadena remain subject to rent caps, just-cause eviction requirements, and the relocation assistance obligations that attach to genuine no-fault evictions. What changed is narrower but practically important.

How DiJulio Law Group Helps Landlords and Property Owners Navigate the Changing Rental Landscape

The California Apartment Association v. City of Pasadena ruling is a reminder that landlord-tenant law in the Los Angeles area is not a static set of rules. It is a layered, evolving framework in which state statutes, local ordinances, and appellate decisions interact — and where the outcome for an individual property owner depends heavily on which rules apply to their specific units, their tenants, and their city.

DiJulio Law Group has represented residential and commercial property owners in eviction and unlawful detainer matters and lease disputes in Glendale, Los Angeles, and throughout Southern California for more than 35 years. We advise landlords on compliance with local rent control and just-cause eviction requirements, represent property owners in unlawful detainer proceedings, and assist clients navigating the notice and documentation requirements that govern when and how a tenancy can be terminated under current California law.

If you own rental property in Pasadena, Glendale, Los Angeles, or the surrounding area and are uncertain whether your units are covered by local rent control, what your relocation obligations are, or how to proceed with an eviction under current law — the time to get that clarity is before a dispute arises, not after it reaches court.