Following Jaramillo v. JH Real Estate Partners Inc. (2003) 111 Cal.App.4th 394 and Harris v. University Village Thousand Oaks, CCRC, LLC. (2020) 49 Cal.App.5th 847, this decision holds that Civ. Code 1953(a)(4) renders unenforceable any arbitration clause in a residential lease–at least so long as the FAA does not apply to the lease.