In Artesia Medical Development Co. v. Regency Associates, Ltd. (1989) 214 Cal. App. 3d 957, an unlawful detainer case, the defendant took possession of the premises under a purported assignment of a lease that it knew the landlord had not consented to, and which the defendant along with the original tenant attempted to conceal. (Id. at p. 960.) The lease contained an attorney fees provision, and the trial court awarded the defendant attorney fees as the prevailing party. (Id. at p. 959.) The court of appeal reversed, ruling that no contractual relationship existed between the defendant and the landlord, and that the defendant was not the prevailing party because the court determined that the assignment was invalid. (Id. at pp. 963-964.)