City of Alameda v. Sheehan
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In May 2017, the City of Alameda leased residential property to Shelby Sheehan. Sheehan stopped paying rent in December 2020 and did not pay for over 17 months. On April 5, 2022, the City served Sheehan with a three-day notice to pay rent or vacate, specifying payment to be made to "City of Alameda c/o River Rock Real Estate Group." Sheehan neither paid nor vacated, prompting the City to file an unlawful detainer action.
Sheehan moved for judgment on the pleadings, arguing the notice was defective because it did not name a natural person as the payee and was ambiguous about the payment method. The trial court agreed, finding the notice invalid for not identifying a natural person and for being ambiguous about acceptable payment methods. Consequently, the court dismissed the action, and the City appealed.
The California Court of Appeal, First Appellate District, reviewed the case de novo. The court disagreed with the trial court's narrow interpretation of "person" under Code of Civil Procedure section 1161(2), holding that "person" includes corporations as well as natural persons. However, the court found the notice defective because it did not provide the correct and complete name of the corporation to whom rent should be paid, creating ambiguity and confusion. Therefore, the court affirmed the trial court's judgment in favor of Sheehan, concluding that the notice did not strictly comply with statutory requirements. The court did not address the trial court's finding of ambiguity based on payment method due to the notice's other deficiencies.
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