In George v. County of San Luis Obispo (2000) 78 Cal.App.4th 1048, lessees of a nonresidential property filed for bankruptcy and their lease was deemed rejected under section 365(d)(4). ( Id. at pp. 1050, 1052.) The bankruptcy court issued an order requiring the debtors " 'and anyone claiming possession under or through them who had notice of these proceedings . . .' " to surrender the property immediately to the City of Morro Bay (presumably the landlord). ( Id. at p. 1050.) Three individuals, who were not the debtors but were in possession of the property and forcibly removed, sued local law enforcement officials for wrongful eviction. (Ibid.) They argued "that, even if the bankruptcy court may compel surrender of leased premises by the bankrupt, it does not follow that the bankruptcy court may compel surrender by third persons claiming an interest in the lease--namely, themselves." ( Id. at p. 1053.) The Court of Appeal rejected this argument, finding the bankruptcy court's order consistent with Ninth Circuit case law. (Ibid.)