Is a tenant required to obtain an eviction certificate before filing an unlawful detainer action for possession of a rent-controlled apartment?

Arguably, the local ordinance's conviction requirement imposes a procedural hurdle that interferes with the state eviction statutes, raising a possible preemption issue (see, e.g., Birkenfeld v. City of Berkeley (1976) 17 Cal.3d 129 [state eviction statutes preempted local rent control ordinance's requirement of obtaining eviction certificate before filing unlawful detainer action for possession of rent-controlled apartment]), but these issues are beyond the scope of this opinion.