California, United States of America
The following excerpt is from California Livestock Production Credit Assn. v. Sutfin, 165 Cal.App.3d 136, 211 Cal.Rptr. 152 (Cal. App. 1985):
3 The retaliatory eviction defense in actions between lessors and lessees is set forth in Civil Code section 1942.5. However, that statute provides remedies that are in addition to remedies provided by decisional common law. ( 1942.5, subd. (h); Barela v. Superior Court, supra, 30 Cal.3d at pp. 250-251, 178 Cal.Rptr. 618, 636 P.2d 582.) Therefore, the statute does not limit the defense to lessor-lessee relationships.
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