Well, eviction is a last line of defense. But, I had a tenant once that moved in, bounced the check, and had no intention of paying rent. Took me 3 months to get them out. So, I know first hand that there are scum bags like that out there and you can bet they are loving having a government partner in perpetrating their fraud.
My experience with Judges is that they are like Grizzly bears. Each has a unique personality. I have had them bounce an eviction case on a tenant that didn't even show up just because they didn't like the Font used on the 3D Notice.
Anyway, I think as long as this CDC Moratorium is in effect, writing M2M leases is a wise strategy to protect against this type tenant.