Can a plaintiff recover damages arising from the breach of a lease where the lease was breached within a single unlawful detainer action?

California, United States of America


The following excerpt is from Sherman v. Yin, B286314 (Cal. App. 2018):

Despite respondent's claim to the contrary, the public policy of judicial economy and efficiency does not support allowing recovery of damages arising from the breach of the lease within a single unlawful detainer action. The purpose of unlawful detainer actions "is to expedite return of possession of real property wrongfully withheld or detained. [Citation.] To this end, '[t]he [unlawful detainer] statutes prevail over inconsistent general principles of law and procedure because of the special function of unlawful detainer actions to restore immediate possession of real property. [Citations.]'" (Hudec v. Roberston, supra, 210 Cal.App.3d at p. 1162.) Any statutory allowance of

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