Dr. Leevil, LLC, Plaintiff and Respondent v. Westlake Health Care Center, Defendant and Appellant.

Summary

The court held that a purchaser acquiring property through a deed-of-trust power of sale must perfect title, including recording the trustee's deed, before serving the three-day notice to quit required for an unlawful detainer action. Because Dr. Leevil served its notice before recording the deed, the notice was premature and void, and the unlawful detainer action was improper. The court therefore reversed the Court of Appeal's judgment.