What is the legal test for a motion to quash in an unlawful detainer action?

In 1983, the motion to quash was judicially redefined for unlawful detainer cases. (See Delta, supra, 146 Cal.App.3d at pp. 10341037, 194 Cal.Rptr. 685.) The requirement that a tenant be properly served with a three-day notice to quit has taken on the role of not only an element in the action but also a prerequisite to obtaining personal jurisdiction over the tenant. (See ibid. ) The apparent thought process behind cloaking the notice requirement with jurisdictional ramifications is this: if there is no valid three-day notice, the summons corresponding to the complaint is necessarily invalid because the truncated time for an answer provided therein is conditioned on a valid three-day notice. Following this logic, a tenant served with an unlawful detainer complaint may, like petitioner, file a Delta motion to quash the summons on the ground that the three-day notice was not properly served. Delta has created confusion and uncertainty among some practitioners ... because the requirement of a properly served three-day notice is an element of an unlawful detainer action and it is normally a demurrer (as opposed to a motion to quash) that tests the sufficiency of the complaint. (Parsons v. Superior Court (2007) 149 Cal.App.4th Supp. 1, 5, 58 Cal.Rptr.3d 48.)