§ 1166.Complaint Requirements

This is the pleading checklist for every unlawful detainer complaint. It must be verified, with the verifying person's name printed or typed, state the facts supporting recovery, describe the premises with reasonable certainty, and, if the case is based on nonpayment of rent under § 1161(2), state the amount in default. The complaint must also specify how the termination notice was served — satisfied either by completing the service items on a Judicial Council form complaint or by attaching proof of service.

For residential cases, subdivision (d) generally requires attaching a copy of the termination notice and any written lease or rental agreement (along with any addenda that form the basis of the complaint), though those attachments aren't required when the lease is oral, when the landlord doesn't have a copy, or when the case rests solely on nonpayment under § 1161(2). Missing an attachment isn't fatal — the court must grant five days to amend and add it. A complaint based on § 1161a involving residential property must say so in its caption, and filing the complaint triggers issuance of the summons under § 1167.

This section exists in two versions with a narrow difference. The version in effect until January 1, 2027 requires stating the method used to serve the termination notice. The version that becomes operative on that date adds a requirement to also state the date, time, and location where that service was completed — a modest addition meant to make the service record more precise, not a change to any other requirement in this section.