buying a non operational car in Cali.

If the owner passed away, then what is on the title is the big question OR the guy selling it is the executor of the will. All questions you will need to ask.

But, yes. No smog needed for a non-running transfer. Had to do that with my Durango ten years ago as it was not running. It also had back fees, but that reflected in what I was willing to give for it.