Tuesday, January 15, 2019
Dr. Leevil, LLC v. Westlake Health Care Center
Cal. Supreme Court (S241324) 12/17/18
Under C.C.P. Section 1161a(b), after a trustee's sale, 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. Accordingly, an unlawful detainer action cannot proceed where the three-day notice is served before recordation of the trustee's deed, even where the trustee's deed is recorded prior to filing the action.