There is no absolute requirement that the tenant contact the former landlord before suing. However, to set up the landlord for bad faith retention penalties, it always helps to prove that the tenant tried contacting the landlord beforehand.
Frank W. Chen has been licensed to practice law in California since 1988. The information presented here is general in nature and is not intended, nor should be construed, as legal advice for a particular case. This posting does not create any attorney-client relationship with the author. For specific advice about your particular situation, please consult with your own attorney.