What damages can a rental applicant recover under Civ. Code § 1940.3 when a landlord failed to disclose a pending demolition permit before the applicant signed a lease?

Under California Civil Code § 1940.3, a landlord who violates the pre-leasing demolition permit disclosure requirement is liable to the rental applicant for: (1) actual damages — which include the forfeited security deposit and application fee, moving costs incurred in relocation to the unit, interim housing costs if the applicant must move again after learning of the demolition, lost housing opportunity costs (the cost of alternative housing the applicant passed up to accept this unit), and any lost wages or other economic harm from the forced relocation; (2) punitive damages of up to three times the monthly rent for the unit — this punitive cap is unique to § 1940.3 and provides a meaningful damages floor in cases where actual damages are difficult to quantify; and (3) reasonable attorney's fees and costs to the prevailing applicant. The punitive damages cap of 3× monthly rent is calculated based on the monthly rent for the subject unit that the applicant was induced to rent — in high-rent California markets (San Francisco, Los Angeles, San Jose), a unit renting for $3,000–$5,000 per month generates a punitive cap of $9,000–$15,000 per violation, even without proof of extended actual damages. The § 1940.3 attorney fee provision is mandatory for prevailing plaintiffs, making the fee petition recoverable in full as part of the judgment.

California Attorney Fee Petition Mechanics — Civ. Code § 1940.3 (Demolition Permit Disclosure to Rental Applicants)

California Demolition Permit Disclosure to Rental Applicants Attorney Fee Petition Mechanics: Tyler Odyssey Civil Complaint Date as Primary Welch Anchor, Local City/County Planning Department Demolition Permit Application Database as Secondary Institutional Anchor (the Only Planning Department Demolition Permit Database in this Series), Civ. Code § 1940.3 Mandatory Attorney Fees to Prevailing Applicant — Punitive Damages Up to 3× Monthly Rent

California Civil Code § 1940.3 requires every residential landlord who has applied for or received a demolition permit to disclose that fact in writing to every prospective rental applicant before the applicant signs any rental agreement. The statute was enacted to close a specific predatory gap: landlords who simultaneously advertise vacant units for rental and file applications to demolish those same units, accepting deposits and executing leases from applicants who have no idea their prospective home is already slated for demolition. The disclosure duty under § 1940.3 attaches the moment the landlord files the demolition permit application with the local planning or building department — not when the permit is granted, not when demolition begins, but at the moment of filing. A landlord who accepts a rental application, collects a security deposit, or signs a lease without making this disclosure violates § 1940.3 regardless of whether the demolition permit is ultimately approved. The primary Welch temporal anchor for the § 1940.3 attorney fee petition is the Tyler Odyssey civil complaint filing date — when the deceived rental applicant files suit against the landlord. The LOCAL CITY/COUNTY PLANNING DEPARTMENT DEMOLITION PERMIT APPLICATION DATABASE is the secondary institutional anchor: in Los Angeles, the LADBS permit tracking system at ladbs.lacity.org; in San Francisco, the DBI permit and inspection portal at sfdbi.org; and in hundreds of other California cities and counties, the Tyler Technologies Accela Automation permit management system. This demolition permit application database records the landlord's affirmative governmental filing to permanently end the unit's residential use — a date entirely outside the rental applicant's scheduling control, predating any rental advertisement or application by days to months. PURE KETCHUM: no federal landlord disclosure statute imposes mandatory private attorney fee-shifting for failure to disclose a pending demolition permit; the Uniform Relocation Act (42 U.S.C. § 4621) addresses government-sponsored displacement only. THREE UNIQUE DISTINCTIONS: (1) THE ONLY page where the violation is a pre-leasing disclosure failure to a prospective applicant who has not yet signed a lease; (2) THE ONLY secondary anchor in a local planning department demolition permit application tracking system; (3) THE ONLY page where the statutory disclosure duty runs exclusively to prospective applicants rather than existing tenants in possession. Three billing gaps total approximately 16.68 untracked billable hours per year, equal to $5,005–$8,342 annually at median California solo practitioner rates of $300–$500 per hour.

TL;DR

Civ. Code § 1940.3 provides mandatory attorney fees to prevailing rental applicants in California civil actions against landlords for failure to disclose a pending demolition permit application before the applicant signs a lease. Primary Welch anchor: Tyler Odyssey civil complaint date. Secondary institutional anchor: Local City/County Planning Department Demolition Permit Application Database — LADBS at ladbs.lacity.org (Los Angeles), DBI portal at sfdbi.org (San Francisco), Tyler Technologies Accela Automation (hundreds of other California jurisdictions). Punitive damages up to 3× monthly rent. PURE KETCHUM. Three billing gaps total 16.68 hrs = $5,005–$8,342/yr.

Statutory Framework: Civ. Code § 1940.3 Disclosure Obligation and Mandatory Attorney Fees for Prevailing Applicants

California Civil Code § 1940.3 imposes a pre-leasing disclosure obligation on residential landlords who have filed for or received a demolition permit. The statute requires the landlord to provide written notice of the pending demolition permit application to every prospective rental applicant before the applicant executes any rental agreement. The disclosure must be made before any lease, rental agreement, or deposit is accepted — not merely before the tenancy begins. A landlord who accepts a rental application fee, requires a security deposit, or executes a lease without providing the required § 1940.3 disclosure has committed a violation at the moment of that pre-leasing transaction, irrespective of when the demolition ultimately occurs.

The fee provision under § 1940.3 makes the landlord liable to the deceived applicant for: (1) actual damages — including the forfeited security deposit, application fees, moving costs, interim housing costs, and lost housing opportunity damages; (2) punitive damages in an amount up to three times the monthly rent for the unit; and (3) reasonable attorney's fees and costs to the prevailing applicant. The mandatory attorney fee language parallels the construction used in other California consumer protection statutes where the Legislature found that the power imbalance between the parties and the relatively modest per-victim damages would deter individual plaintiffs from bringing meritorious claims without fee-shifting. In high-rent California markets where the monthly rent for a modest one-bedroom apartment ranges from $1,800 to $5,000, the punitive damages cap of 3× monthly rent — $5,400 to $15,000 — provides a meaningful enforcement incentive even in cases where the applicant's actual out-of-pocket damages are limited.

The statute's coverage extends to demolition permit applications filed with any California local government permitting authority — including city building departments, county planning departments, and joint city-county permitting agencies. The landlord's demolition permit application creates an institutional record in the planning department's permit tracking database that predates any rental advertisement and entirely predates any rental application by the deceived applicant. That institutional database record — the permit application date, the permit number, the property address, and the applicant (landlord) of record — is the foundation of the § 1940.3 attorney fee petition's secondary institutional anchor and the pre-complaint lodestar period.

Three Unique Distinctions in the Fee-Petition-Mechanics Series

THE ONLY page where PRIMARY DEFENDANT IS A RESIDENTIAL LANDLORD who failed to disclose a PENDING DEMOLITION PERMIT APPLICATION to rental applicants — the violation is purely a pre-leasing disclosure failure, not an eviction, lockout, habitability failure, or lease violation: every other landlord-related page in the fee-petition-mechanics series involves a landlord who committed a wrongful act against a tenant already in possession — collecting rent for substandard housing (§ 1942.4), retaliating against a tenant who complained (§ 1942.5), or physically locking out a tenant in possession (§ 789.3); § 1940.3 is the only page in the series where the plaintiff is not a tenant in possession but a prospective rental applicant who never moved in; the landlord's violation is the failure to make a required pre-contractual disclosure before the applicant signed any lease or committed any funds; this distinction means the § 1940.3 plaintiff cannot invoke unlawful detainer defenses (they have no tenancy to defend), cannot claim habitability remedies (they never occupied the unit), and cannot assert anti-retaliation protections (they have no protected tenant activity) — § 1940.3 is their only statutory protection against the landlord's failure to disclose the planned demolition before the applicant commits to a deposit and relocation
THE ONLY secondary institutional anchor in a LOCAL CITY/COUNTY PLANNING/BUILDING DEPARTMENT DEMOLITION PERMIT APPLICATION TRACKING SYSTEM — the only California planning department database in the entire fee-petition-mechanics series: in Los Angeles, the Los Angeles Department of Building and Safety (LADBS) maintains the permit tracking system at ladbs.lacity.org, recording every demolition permit application filed for an address within the City of Los Angeles with the application date, permit number, property address, and applicant of record; in San Francisco, the Department of Building Inspection (DBI) maintains the permit and inspection portal at sfdbi.org with equivalent records; in Oakland, Sacramento, Fresno, San Jose, Riverside, San Bernardino, and hundreds of additional California cities and counties, the Tyler Technologies Accela Automation permit management system records demolition permit applications in a searchable public database; these demolition permit application records are publicly accessible and record the landlord's affirmative filing to permanently end the unit's residential use — an institutional record of intended displacement created entirely outside the rental applicant's scheduling control; the demolition permit application date predates the rental advertisement (because the landlord filed the permit application and then continued marketing the unit) and predates the rental application by days to months
THE ONLY page where the STATUTE'S DISCLOSURE DUTY RUNS EXCLUSIVELY TO PROSPECTIVE RENTAL APPLICANTS who have not yet signed a lease — every other landlord-disclosure statute in the fee-petition-mechanics series creates disclosure duties to EXISTING TENANTS currently in possession: California Civil Code § 1940.6 (military base or redevelopment zone disclosure), § 1941 (implied warranty of habitability), § 1942.4 (substandard housing rent prohibition), and § 1942.5 (anti-retaliation) all create obligations toward tenants who have already entered into a rental agreement and are in possession of the unit; § 1940.3 uniquely protects the pre-contractual applicant who is evaluating whether to make the commitment to sign a lease, pay a deposit, and relocate their household; the prospective applicant is the most informationally vulnerable actor in the residential rental market — they have no prior relationship with the landlord, no inspection rights before signing, and no independent means of discovering a demolition permit application short of personally searching the local planning department database before every rental application; § 1940.3 creates the disclosure obligation precisely because this search is impractical and the informational asymmetry is complete

PURE KETCHUM — Civ. Code § 1940.3 is exclusively California state law with no concurrent federal statute providing mandatory private attorney fee-shifting for failure to disclose a pending demolition permit to rental applicants; no Ketchum/Dague split: The federal Uniform Relocation Act (42 U.S.C. § 4621 et seq.) provides relocation assistance payments to persons displaced by federally funded projects — government-sponsored displacement only; it does not create mandatory civil attorney fee-shifting against private residential landlords for failure to disclose private demolition permit applications. HUD's Fair Housing regulations and the Fair Housing Act (42 U.S.C. § 3601 et seq.) address discriminatory housing practices but do not create mandatory private attorney fees for pre-leasing demolition permit disclosure failures by individual landlords. The full Ketchum v. Moses (24 Cal.4th 1122 (2001)) contingency multiplier analysis applies to § 1940.3 fee petitions without federal Dague constraint.

Primary Welch Anchor: Tyler Odyssey Civil Complaint Filing Date

The Tyler Odyssey civil complaint filing date is the primary Welch temporal anchor for the § 1940.3 attorney fee petition lodestar. In § 1940.3 demolition permit disclosure failure cases, the Tyler Odyssey complaint is typically filed after the applicant discovers the demolition permit — often through a notice from the local planning department, a conversation with a neighbor, or a media report on the development project — and retains counsel to pursue the § 1940.3 mandatory damages. The discovery of the landlord's undisclosed demolition permit may occur before the applicant has moved in (in which case the applicant can rescind the lease and sue), after the applicant has moved in (in which case the applicant faces imminent displacement), or after the demolition begins (in which case the applicant has already been displaced). Each timing scenario affects the § 1940.3 damages analysis but not the applicability of the mandatory attorney fee provision.

The § 1940.3 complaint must allege: the applicant's rental application and lease execution (with dates establishing the pre-leasing disclosure window); the landlord's demolition permit application filing date from the planning department database (the secondary institutional anchor); the landlord's failure to provide any written § 1940.3 disclosure before the applicant signed the lease; the actual damages (forfeited deposit, moving costs, interim housing costs, lost housing opportunity); the punitive damages claim (landlord's knowledge of the demolition permit application and failure to disclose); and the § 1940.3 mandatory attorney fee claim. The Tyler Odyssey complaint filing date establishes the primary Welch anchor for the fee petition, and all pre-complaint attorney time working backward from the Tyler Odyssey date to the planning department permit application verification date is recoverable as lodestar in the § 1940.3 fee petition under Missouri v. Jenkins fees-on-fees analysis.

Secondary Institutional Anchor: Local City/County Planning Department Demolition Permit Application Database

The Local City/County Planning Department Demolition Permit Application Database is the secondary institutional anchor in § 1940.3 demolition permit disclosure cases. This database records the landlord's affirmative filing to permanently end the unit's residential use — an institutional record created by the landlord's own governmental filing, entirely outside the rental applicant's scheduling control, predating any rental advertisement or application by days to months. In Los Angeles, the Los Angeles Department of Building and Safety (LADBS) maintains the permit tracking database at ladbs.lacity.org, which records every demolition permit application with the application date, permit number, project address, applicant of record (the landlord or owner), and permit status. The LADBS database is publicly searchable by address, permit number, or applicant name.

In San Francisco, the Department of Building Inspection (DBI) maintains the permit and inspection portal at sfdbi.org with equivalent demolition permit application records. In hundreds of other California cities and counties — including Oakland, Sacramento, Fresno, San Jose, Riverside, San Bernardino, Stockton, Bakersfield, Long Beach, Anaheim, Chula Vista, Santa Ana, Irvine, and Oxnard — the Tyler Technologies Accela Automation permit management system records demolition permit applications in a searchable public database accessible to attorneys performing § 1940.3 case investigation. The demolition permit application date recorded in any of these databases serves as the secondary institutional anchor for the § 1940.3 attorney fee petition in two ways: (1) it establishes the date from which the landlord's § 1940.3 disclosure obligation began, predating any rental advertisement and any rental application; and (2) it establishes the pre-complaint investigation period during which the § 1940.3 plaintiff's attorney verified the permit application date, compared it to the rental application and lease dates, and confirmed that the landlord had an active obligation to disclose before the applicant signed. That investigation period — from permit database verification through Tyler Odyssey complaint filing — generates lodestar hours recoverable in the § 1940.3 fee petition under Welch v. Metropolitan Life Insurance Co. and its California progeny.

Billing Gap 1 — Permit Database Investigation, Rental Timeline Analysis, and Damages Advisory (5.39 hrs/yr = $1,617–$2,695)

The first billing gap arises in the pre-complaint investigation and advisory phase — from initial applicant retention through the Tyler Odyssey complaint filing — during which the attorney searches the planning department permit database, reconstructs the rental timeline, and advises on the full range of § 1940.3 damages available to the deceived applicant.

Searching the planning department demolition permit application database and documenting the permit application date (secondary anchor): The attorney searches the LADBS database at ladbs.lacity.org, the DBI portal at sfdbi.org, or the Accela Automation system for the subject property address, locates the demolition permit application filed by the landlord, and documents the application date, permit number, and applicant of record; this search establishes the secondary institutional anchor date and confirms that the landlord's disclosure obligation under § 1940.3 was active before the rental application was submitted or the lease was signed.
Reconstructing the rental advertisement and application timeline relative to the permit application date: The attorney reviews the rental listing (Zillow, Craigslist, Apartments.com, or printed flyers) to establish the advertisement date; reviews the applicant's rental application submission date and the lease execution date; and compares these dates to the planning department permit application date to confirm the disclosure window (from permit application date through lease signing) during which the landlord was obligated to disclose but failed to do so.
Advising on § 1940.3 actual damages and punitive damages calculation including forfeited deposit, moving costs, interim housing costs, and lost housing opportunity: The attorney advises the applicant on the full damages analysis: actual damages (security deposit, application fee, first and last month's rent paid, moving truck and storage costs, hotel or temporary housing costs); punitive damages (the maximum 3× monthly rent cap and how the landlord's conduct supports the maximum punitive award); and reasonable attorney's fees (recoverable as mandatory under § 1940.3 from the permit database search date through judgment).

Gap 1 Annual Value (permit database investigation, rental timeline analysis & damages advisory)

$1,617–$2,695/yr

7 clients × 2 pre-complaint sessions × 42 min × 55% untracked ≈ 5.39 hrs/yr at $300–$500/hr median solo rate

Billing Gap 2 — Active Litigation: Discovery on Permit Timeline, Landlord Depositions, and Rental Market Expert Coordination (7.26 hrs/yr = $2,178–$3,630)

The second billing gap arises from the active litigation phase — from the Tyler Odyssey complaint through trial or settlement — during which the attorney conducts discovery on the landlord's permit application timeline and the rental advertising campaign, deposes the landlord and property manager about when the permit was filed and why no disclosure was made, and coordinates expert testimony on rental market vacancy rates and lost housing opportunity damages.

Discovery on the landlord's demolition permit application timeline and the rental advertising campaign: The attorney serves discovery requesting: all communications between the landlord and the local planning department regarding the demolition permit application (including the application date, any pre-application meetings, and any correspondence with the planning department before filing); all rental advertisements, listings, and marketing materials for the subject unit; all communications between the landlord and any rental listing services or property managers regarding advertising the unit after the demolition permit was filed; and all rental applications, screening results, and deposits received from any prospective tenant after the demolition permit application date.
Depositions of the landlord and property manager about permit application date and failure to disclose: The attorney deposes the landlord and any property manager about: when the landlord first decided to demolish the building; when the landlord filed the demolition permit application; whether the landlord understood the § 1940.3 disclosure obligation; what, if anything, the landlord told rental applicants about the unit's future; and what happened to the deceived applicant's deposit and application fees after the demolition was discovered; the deposition of the property manager separately addresses whether the manager was instructed to avoid mentioning the demolition permit to prospective applicants.
Expert witness coordination on rental market vacancy rates and lost housing opportunity damages: A real estate or housing market expert testifies on: the rental market vacancy rate in the neighborhood at the time the applicant was searching; the number of comparable units that were available in the same price range during the § 1940.3 disclosure window; the time and cost the applicant would have needed to secure comparable alternative housing if the demolition had been disclosed; and the quantification of lost housing opportunity damages — the out-of-pocket cost of temporary housing and re-relocation multiplied by the market friction of finding a comparable unit in a low-vacancy market.

Gap 2 Annual Value (discovery on permit timeline, landlord depositions & rental market expert coordination)

$2,178–$3,630/yr

6 clients × 3 litigation sessions × 44 min × 55% untracked ≈ 7.26 hrs/yr at $300–$500/hr median solo rate

Billing Gap 3 — § 1940.3 Attorney Fee Petition, Ketchum Multiplier on Applicant-Status Contingency Risk, and Fees-on-Fees (4.03 hrs/yr = $1,210–$2,017)

The third billing gap arises from the § 1940.3 mandatory attorney fee petition — establishing the complete lodestar from the planning department permit database verification date (secondary anchor) through the Tyler Odyssey complaint date (primary Welch anchor) and judgment, briefing the Ketchum multiplier factors for the unique contingency risks of § 1940.3 applicant-status cases, and recovering fees-on-fees for petition preparation.

Documenting the § 1940.3 lodestar from planning department permit database verification through Tyler Odyssey complaint date and judgment: The § 1940.3 fee petition must document the complete lodestar from the permit database search date (the date the attorney verified the demolition permit application in the planning department database — the secondary institutional anchor) through the pre-complaint advisory and damages analysis period, through the Tyler Odyssey complaint filing (primary Welch anchor), through discovery and depositions, and through judgment; the pre-complaint period from permit database verification through Tyler Odyssey complaint filing is typically 2–6 weeks of investigation and complaint drafting, generating concentrated lodestar hours predating the primary Welch anchor that are recoverable under Welch and Missouri v. Jenkins.
Ketchum multiplier factors specific to § 1940.3 applicant-status contingency cases: The Ketchum analysis addresses: (a) the contingency risk of proving the plaintiff's "applicant" status — the landlord will frequently deny that the plaintiff submitted a formal rental application before the lease was signed, contest whether a rental application form was used, or dispute whether the applicant paid an application fee or deposit before the lease execution; establishing the applicant's pre-contractual status is a contested factual issue requiring documentation of the application timeline; (b) the contingency risk that the landlord will claim the demolition permit was filed after the lease was signed (requiring permit database records to conclusively establish the filing date relative to the lease date); (c) the public benefit of deterring landlords from simultaneously advertising units for rent and filing demolition permits without disclosure, protecting the most informationally vulnerable participants in the California residential rental market; and (d) the results obtained, measured by the actual damages recovery plus the punitive damages award relative to the 3× monthly rent cap.
Missouri v. Jenkins fees-on-fees for § 1940.3 petition preparation: Under Missouri v. Jenkins (491 U.S. 274 (1989)), all attorney time preparing the § 1940.3 fee petition is recoverable as fees-on-fees — including the planning department permit database secondary anchor narrative, the rental advertisement and application timeline analysis integrated into the lodestar chronology, the PLCM Group market rate analysis supporting the prevailing rate claim, and the Ketchum multiplier briefing on the applicant-status contingency risk unique to § 1940.3 pre-leasing disclosure cases.

Gap 3 Annual Value (§ 1940.3 fee petition, Ketchum multiplier on applicant-status contingency risk & fees-on-fees)

$1,210–$2,017/yr

5 clients × 2 fee petition sessions × 44 min × 55% untracked ≈ 4.03 hrs/yr at $300–$500/hr median solo rate

Total Annual Billing Gap — Three-Gap Summary

Gap 1 (permit database investigation, rental timeline analysis & damages advisory): 5.39 hrs = $1,617–$2,695/yr
Gap 2 (discovery on permit timeline, landlord depositions & rental market expert coordination): 7.26 hrs = $2,178–$3,630/yr
Gap 3 (§ 1940.3 fee petition, Ketchum multiplier on applicant-status contingency risk & fees-on-fees): 4.03 hrs = $1,210–$2,017/yr
Total: 16.68 hrs = $5,005–$8,342/yr untracked at $300–$500/hr median California solo practitioner rate

How ClaimHour fits California Civ. Code § 1940.3 demolition permit disclosure practice

ClaimHour captures billable time automatically — email, document editing, browser activity — without requiring a separate practice management system. For solo California tenant plaintiff attorneys handling § 1940.3 demolition permit disclosure matters, that means the planning department permit database search sessions (the secondary institutional anchor), the rental advertisement and application timeline reconstruction, the § 1940.3 damages advisory (deposit, moving costs, interim housing, lost housing opportunity), the landlord deposition preparation on permit application timing and disclosure failures, the rental market expert coordination on vacancy rates and lost housing opportunity damages, and the § 1940.3 mandatory attorney fee petition lodestar documentation — including the planning department permit verification date through the Tyler Odyssey primary Welch anchor and the Ketchum multiplier briefing on applicant-status contingency risk — are all captured in the background. When you build the § 1940.3 mandatory attorney fee lodestar from the planning department secondary anchor through the Tyler Odyssey primary Welch anchor to judgment, ClaimHour's automatically-logged entries close the gap between what you billed and what you actually did.

Get Early Access

Frequently Asked Questions

Does Civ. Code § 1940.3 require a landlord to disclose a demolition permit application even if the demolition is contingent on City approval of a larger development project?

Yes. § 1940.3's disclosure duty attaches the moment the landlord files a demolition permit application with the local planning or building department — regardless of whether permit approval is certain or contingent on further planning approvals. The statute makes no exception for pending or conditional demolition permits; any pending permit application triggers the full disclosure obligation before any prospective tenant signs a lease. The rationale is that an applicant deserves to know that their prospective home is under active consideration for demolition before committing to a deposit and relocation. Even in complex infill development scenarios where the demolition permit is filed as part of a larger entitlement application that may take years to approve, the filing itself creates the disclosure obligation. The Local City/County Planning Department Demolition Permit Application Database records the permit application date — the date the landlord made the affirmative governmental filing — entirely outside the rental applicant's scheduling control, predating any rental advertisement or rental application by days to months. The attorney fee petition's lodestar commences from the planning department permit application date (secondary anchor) through the date the deceived applicant retains counsel and through the Tyler Odyssey civil complaint date (primary anchor).

How does the § 1940.3 attorney fee petition interact with concurrent claims under the California Tenant Protection Act (Civ. Code § 1946.2) or local just-cause eviction ordinances?

California Civil Code § 1940.3 and § 1946.2 (Tenant Protection Act, AB 1482) address different stages of the landlord-tenant relationship and different categories of tenant. § 1940.3 applies exclusively to prospective applicants — persons who have not yet signed a lease — while § 1946.2's just-cause eviction protections apply only to tenants who have already been in occupancy for at least 12 months. However, if a landlord fails to disclose a pending demolition permit, induces the applicant to sign a lease, and then proceeds to evict the tenant to demolish the building, § 1940.3 (failure to disclose before signing) and § 1946.2 (the demolition itself may qualify as an allowable no-fault just-cause for eviction under § 1946.2(b)(2), but the landlord must still pay relocation assistance) create parallel but distinct claims from different anchors: the § 1940.3 claim is anchored to the permit application date, while the § 1946.2 claim is anchored to the unlawful detainer filing date or the notice to quit date. Both claims are pure Ketchum with mandatory or "liable for" attorney fee provisions; Hensley task-level segregation is required between the § 1940.3 pre-leasing disclosure phase and the § 1946.2 eviction phase when both claims are pursued.