§7.04 Damage Action Against Tenant

The landlord has the option of maintaining an independent civil action for damages against the tenant, either after the tenant surrenders possession or abandons the property or in conjunction with a summary proceeding for unlawful detainer. [See Northrop Corp. v Chaparral Energy, Inc. (1985) 168 CA3d 725, 729–730.] Combining the two actions may be the correct choice when the tenant has done significant damage to the rental unit or when there are other elements of damage that are not cognizable in a UD action.