Saxonis Realty Holdings, LLC v. Nicole Westfall, et. al 25H83SP00249TA

In this housing court decision Judge Salvidio denied a motion for summary judgment where the tenant's attorney argued that a 30 day notice to quit in a non-payment proceeding was required because the tenant had a section 8 voucher. 

The court found that the CARES act's 30 day notice to quit requirement had expired as part of the original 120 moratorium. 

The court read paragraph 9058(c) in context with the rest of the section to find that not finding an expiration date would lead to an absurd result extending the 30 day notice requirement indefinitely and to all types of proceedings. The court also summarized which states have found the 30 day notice is still in effect and which do not.  Further the court ruled that the 30 day notice should not be read to remain in effect because doing so would presume Federal preemption of state law.