Imperial Beach passed its own Just Cause for Termination of a Residential Tenancy Ordinance in February 2025, and it layers real notice, filing, and relocation requirements on top of state law — but it does not move California’s 12-month just-cause threshold the way the City of San Diego’s ordinance does.

For a landlord planning to sell a tenant-occupied house in this small South Bay city, knowing exactly which rule applies, and when, is the difference between a clean closing and a tenancy problem that surfaces in escrow.

Table of Contents

Where This Ordinance Lives and Why It Exists

Imperial Beach’s City Council adopted Ordinance No. 2025-1253 on February 19, 2025, adding Chapter 9.90 to the Imperial Beach Municipal Code.

The chapter states its own purpose plainly: to require just cause for termination of residential tenancies consistent with California Civil Code Section 1946.2, to further limit the reasons a tenancy can be ended, to require greater relocation assistance in specified circumstances, and to add additional local regulations on top of the state framework.

Where state or federal law provides stronger tenant protections than the local ordinance, the stronger protection controls — the city’s own text says so directly.

The 12-Month Threshold — Not Day One

This is the detail that most often gets confused with San Diego’s rule just a few miles up the coast. Under Section 9.90.050(A), after a tenant has continuously and lawfully occupied a unit for 12 months, an owner cannot terminate the tenancy without just cause.

That mirrors the 12-month threshold in the state’s own Civil Code Section 1946.2. San Diego’s city ordinance, by contrast, requires just cause from the very first day of a covered tenancy — a materially stricter rule.

Imperial Beach’s ordinance adds real obligations on top of state law, but it does not change when just cause starts applying in the first place.

At-Fault and No-Fault Just Cause, as the Ordinance Defines Them

Section 9.90.050(B) adopts the same at-fault just cause grounds found in Civil Code Section 1946.2(b)(1): nonpayment of rent, breach of a material lease term after notice to cure, nuisance, waste, criminal activity at the unit, unlawful subletting, refusal to allow lawful entry, using the unit for an unlawful purpose, and a few related grounds tied to California Code of Civil Procedure Section 1161.

No-fault just cause under Section 9.90.050(C) covers four situations: the owner or a qualifying family member intends to occupy the unit as a primary residence for at least 12 consecutive months; the tenancy is being ended to comply with a government or court order relating to habitability, or a local ordinance requiring the unit to be vacated; the owner is withdrawing the unit from the rental market entirely; or the owner intends to substantially remodel or demolish the unit.

Each of these carries its own notice and, in most cases, relocation assistance obligations that at-fault terminations don’t.

Relocation Assistance Tied to HUD’s Fair Market Rent, Not a Flat Dollar Figure

Imperial Beach’s relocation formula is unusual among California’s local tenant protection ordinances, most of which use a flat dollar figure or a multiple of the contract rent.

Under Section 9.90.060, when an owner ends a no-fault tenancy, they must either pay the tenant, or waive in writing, an amount equal to one month of the U.S. Department of Housing and Urban Development’s Small Area Fair Market Rent for the unit’s ZIP code at the time the termination notice was issued, plus one month of the tenant’s actual contract rent.

If the tenant is elderly — defined in the ordinance as 62 or older — or disabled, that relocation amount doubles to two months of the HUD Small Area Fair Market Rent plus one month of contract rent.

Because HUD’s Small Area Fair Market Rent figures are published and updated by ZIP code, the dollar amount actually owed changes depending on exactly where in Imperial Beach the unit sits and when HUD last updated the figure — it isn’t a single citywide number a landlord can memorize once and reuse.

The Three-Business-Day Notice to the City

Beyond notifying the tenant, the ordinance requires the owner to give the City of Imperial Beach written notice of any just-cause termination — at-fault or no-fault — no later than three business days after the tenant is served, using a form the city has approved for that purpose.

Imperial Beach maintains a Mandatory Eviction Notice Filing Page specifically for this requirement under Section 9.90.060(A)(1).

Skipping this filing isn’t a minor paperwork lapse: under Section 9.90.060(C)(5), an owner’s failure to strictly comply with the chapter’s notice requirements can render the termination notice void outright, which means a defective filing can undo an otherwise valid eviction.

Substantial Remodel Comes With a Right to Re-Rent

The ordinance defines a substantial remodel narrowly: replacing or substantially modifying a structural, electrical, plumbing, or mechanical system under permit, or abating hazardous materials such as lead paint, mold, or asbestos — and only when the work genuinely can’t be done safely with the tenant still in the unit for at least 30 consecutive days.

Purely cosmetic work, including painting, flooring, cabinets, countertops, or minor repairs that don’t require vacating the unit, doesn’t qualify no matter how extensive it looks on paper.

Critically, if the remodel or demolition described in the termination notice is never actually commenced or completed, the owner must offer the former tenant the chance to re-rent the same unit on the same lease terms and at the same rent that was in effect when they vacated.

The tenant then has 30 days to accept or reject that offer, and if they accept, 30 more days to reoccupy.

A landlord who terminates a tenancy citing a remodel that never happens — intentionally or not — can end up owing the former tenant reimbursement for moving costs and be obligated to offer the unit back on terms set before any sale.

The Written Notice Every Covered Tenant Must Receive

Section 9.90.050(D) requires every owner of a covered unit to provide tenants a specific written notice, either directly or as a lease addendum, stating: “California law limits the amount your rent can be increased. See California Civil Code section 1947.12 for more information.

Local law also provides that after a tenant has continuously and lawfully occupied the property for 12 months or more, a landlord must provide a statement of cause in any notice to terminate a tenancy.” For a tenancy that existed before the chapter took effect, that notice had to be delivered by March 22, 2025.

For any tenancy commenced or renewed after that date, it has to be included as a lease addendum or a separately signed notice from the start.

A landlord who never provided this notice is exposed to the same enforcement remedies as one who got a termination wrong — it isn’t just a formality the city expects to be overlooked.

The Business License Acknowledgment and Return of Deposit

Two smaller but easy-to-miss requirements round out the chapter.

Under Section 9.90.050(F), when an owner applies for a City of Imperial Beach business license to operate a rental, they’re required to acknowledge in writing that they’ve read and will abide by Chapter 9.90 if it applies to the unit — a business license application is therefore also, functionally, a compliance checkpoint for this ordinance.

Separately, Section 9.90.060(B)(1)(d) requires that any security deposit be returned within the timeframe already set by state law, regardless of what relocation assistance is owed on top of it — the two obligations run independently and neither offsets the other.

How Imperial Beach Compares to Its Neighbor, Chula Vista

Imperial Beach is one of only a handful of San Diego County cities with a general tenant protection ordinance of this kind layered on top of state law — the others being the City of San Diego and Chula Vista.

We’ve covered other San Diego County disclosure requirements separately, but it’s worth noting how differently these three cities built their own rules even though they sit in the same county.

Chula Vista’s Municipal Code Chapter 9.65 also imposes just cause from day one rather than after 12 months, sets a substantial-remodel cost floor of $40 per square foot before that justification can be used at all, and requires its own three-business-day notice to the city on a no-fault termination.

Imperial Beach’s ordinance shares the three-day city-notice concept and the substantial-remodel re-rent protections, but keeps the state’s 12-month threshold rather than moving to day one, and ties its relocation formula to HUD’s published Fair Market Rent rather than a flat local figure.

The lesson for a landlord with property in more than one of these cities is that none of these ordinances can be assumed to work the same way just because they sit a few miles apart.

Who’s Exempt

Section 9.90.040 carves out exemptions that largely track the state Tenant Protection Act’s own exemptions. Single-family owner-occupied homes where the owner rents out no more than two units or bedrooms, including an ADU or JADU, are exempt.

A duplex where the owner occupies one unit as their principal residence is exempt, as long as neither unit is an ADU or JADU. Housing issued a certificate of occupancy within the previous 15 years is exempt unless it’s a mobile home.

Mobile home residents covered separately under the Mobilehome Residency Law, transient hotel stays, short-term rentals of 30 days or less, and deed-restricted affordable housing are all carved out as well.

There’s also a specific exemption for a single-family home or condo that’s alienable separately from any other unit, provided the owner isn’t a real estate investment trust, a corporation, or an LLC with a corporate member, and provided the tenant has been given a specific written notice — required in the lease itself for any tenancy starting on or after March 22, 2025 — stating plainly that the property is exempt from both the rent cap in Civil Code Section 1947.12 and the just-cause requirements of Civil Code Section 1946.2 and Chapter 9.90.

Skipping that written notice can mean losing the exemption even if the property would otherwise qualify.

What a Seller With Tenants in Place Actually Needs to Resolve

Selling a tenant-occupied house in Imperial Beach doesn’t require ending the tenancy at all, and in most cases it shouldn’t — most buyers, including cash buyers, are perfectly comfortable taking title subject to an existing lease and simply stepping into the landlord’s position without anyone ever being served a termination notice.

The ordinance only becomes relevant if a termination is on the table, whether because a buyer wants vacant possession or because the seller plans to terminate before listing.

In either case, a seller should confirm: whether the tenant has lived there 12 months or more, which just-cause grounds would actually apply, what written notice has already been given to the tenant about their rights under state and local law, and whether the business license acknowledgment required under Section 9.90.050(F) — the step where an owner confirms to the city, when applying for a business license, that they’ve read and will follow this chapter — is actually on file.

Enforcement and the Sunset Clause

A tenant who believes the ordinance was violated can sue in civil court for injunctive relief, actual damages, and in the case of willful, oppressive, or malicious conduct, up to three times actual damages, plus attorney’s fees awarded at the court’s discretion rather than as an automatic entitlement.

The City of Imperial Beach can also pursue its own civil and criminal enforcement independently of any private lawsuit.

The ordinance is not permanent as written: Chapter 9.90 is set to remain in effect only until January 1, 2030, and repeals automatically on that date unless the City Council acts to extend it — worth knowing if you’re structuring a long-term hold rather than a near-term sale.

Because enforcement can come from either the tenant directly or the city itself, a landlord can’t assume a quiet tenant means a compliant file.

A former tenant who moves out without objection can still bring a claim well after the fact if the paperwork didn’t match what the chapter required at the time, and the three-times-damages exposure for willful or oppressive conduct applies whether or not the owner intended to cut corners.

That’s part of why documenting each step as it happens, rather than reconstructing it later from memory, matters so much here.

When a Cash Sale Is the Wrong Choice

If the tenancy is straightforward, rent is current, no termination is planned, and you have the time to market the property to a buyer pool that includes landlords looking for an occupied investment property, a conventional sale with the lease assigned at closing will usually bring a better price than a direct cash sale.

Buy-and-hold investors specifically look for occupied, income-producing properties and will often pay a premium for one with a clean rent roll and no pending notice disputes.

A direct sale tends to make more sense when a termination has already gone wrong procedurally — a notice that didn’t meet the ordinance’s requirements, or relocation assistance that was calculated incorrectly or never paid — and resolving it would take months a seller doesn’t have; when the tenant relationship has broken down and a buyer with experience handling occupied or disputed tenancies is genuinely better positioned to take it on; or when the relocation costs required under the ordinance, calculated against current HUD Fair Market Rent figures, are themselves a meaningful share of what the sale would net.

A seller who inherited the property and never dealt with the tenant personally is often in exactly this position, inheriting both a lease and a set of compliance obligations they never agreed to and didn’t create.

First Steps

Confirm how long the current tenant has continuously occupied the unit — the 12-month threshold decides whether Chapter 9.90 even applies yet
Identify which just-cause ground, if any, actually applies before drafting a termination notice
Calculate relocation assistance against the current HUD Small Area Fair Market Rent for the unit’s ZIP code, not an outdated figure
File the required notice with the City within three business days of serving the tenant
Keep a copy of every notice, filing, and payment in case the termination is later challenged

Imperial Beach’s ordinance rewards getting the paperwork right the first time, with every deadline and dollar figure spelled out in the code, and punishes getting it wrong harshly, with a defective notice voided outright and statutory damages running against the owner.

If you’d rather sell a tenant-occupied Imperial Beach property as-is, with the lease and the notice history handled by a buyer who deals with this regularly, Cash Home Buyers CA can make a no-obligation cash offer, and our Imperial Beach tenant-occupied page has more on how that process works.

You can also see Cash Home Buyers CA on our Google Business Profile.

Imperial Beach’s Just Cause Ordinance: What a Landlord Selling a Rental Must Clear First