Legal Question in Real Estate Law in California

I believe so; the law does not mention life estates, but it does exclude leases with an unexpired term of less than two years or personal property (Code of Civil Procedure section 704.740(b) from certain protection. Since a life estate, like a fee simple, is considered a "freehold" estate, it is probably entitled to the same protection. This is also implied in an appellate court decision on a closely-related topic in Arighi v. Rule & Sons, Inc. (1940) 41 Cal.App.2d 852.