For a tenant to establish a breach of the implied covenant of quiet enjoyment resulting from a landlord’s conduct in connection with a rental agreement, “minor inconveniences and annoyances are not actionable breaches of the implied covenant of quiet enjoyment. To be actionable, the landlords act or omission must substantially interfere with a tenant’s right to use and enjoy the premises for the purposes contemplated by the tenancy.” See Andrews v. Mobile Aire Estates, (2005) 125 Cal. App. 4th 578, 589. Additionally, the person causing the interference need not be the landlord personally, but rather an actionable breach may lie where the interference is caused by a neighbor or tenant claiming under the landlord. See Petroleum Collections, Inc. v. Swords, (1975) 48 Cal. App. 3d 841, 846. Thus, landlords should remain mindful of not only the nature of the breach complained of but also the source as the actions of another tenant or third person may still expose the landlord to liability.