In Miller & Desatnik Management Co. v. Bullock (1990) 221 Cal. App. 3d Supp. 13 270 Cal. Rptr. 600, the question of whether the defendant in an unlawful detainer action was a tenant was directly addressed. Bullock was the mother of the tenant, who had died four years before the unlawful detainer was filed. Her daughter had rented the premises under a written month-to-month agreement. Bullock concealed her daughter's death from the plaintiff and paid rent in her daughter's name. She did not live in the apartment, but visited it frequently. Upon discovering the death of the tenant, the plaintiff immediately served a notice to vacate and stopped accepting rent. (Id. at pp. Supp. 15-16.) The Court first determined, under general state law, that the death of the tenant under a month-to-month tenancy terminates the tenancy on the 30th day following the last payment of rent by the tenant prior to her death. (Id. at pp. Supp. 18-19.) The Court next determined that Bullock was not a tenant by looking to the definition of tenant in the Santa Monica Rent Control Charter Amendment. The Court found that Bullock did not come within that definition and was therefore not entitled to protection under the amendment. (221 Cal. App. 3d at pp. Supp. 19-20.)