In White v. Pfieffer (1913) 165 Cal. 740, the court interpreted section 1172, defining a prima facie case. There, the defendant-appellant argued that forcible detainer required previous actual possession of the property by the plaintiff. ( Id. at p. 742.) The facts in White were that the plaintiff's premises were vacant when defendant took them over, and plaintiff had previously had tenants there. However, the court stated that under section 1172, "a plaintiff shall only be required to show that he 'was entitled to the possession at the time of the forcible detainer.'" (Ibid.)