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Cal. Apartment Assn. v. City of Pasadena (2025)

Citation
Cal. Apartment Assn. v. City of Pasadena (2025)
Parent Document
Cal. Apartment Assn. v. City of Pasadena (2025)
Jurisdiction
California (state)
Effective Date
2025-12-18

Other Sections in This Document (114)

Full Text

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43
jurisprudence”].) And petitioners provide no authority
demonstrating a class comprising anyone who may not hold one
of the seven tenant positions—that is, any Pasadena resident
who is not a Tenant or is in possession of a Material Interest in
Rental Property—is a suspect one. Accordingly, we examine
whether there is any “ ‘ “rational relationship between the
disparity of treatment and some legitimate governmental
purpose.” ’ ” (Johnson, at p. 881.)
             c.    The Rental Board composition survives rational
                   basis review
       “To mount a successful rational basis challenge, a party
must ‘ “negative every conceivable basis” ’ that might support the
disputed statutory disparity. [Citation.] If a plausible basis
exists for the disparity, courts may not second-guess its
‘ “wisdom, fairness, or logic.” ’ ” (Johnson, supra, 60 Cal.4th at
p. 881; accord, Hardin, supra, 15 Cal.5th at p. 864.) The burden
is on the challenger to show the absence of a rational relationship
between the disparity in treatment and some legitimate
government purpose. (Warden, supra, 21 Cal.4th at p. 641;
accord, Hardin, at p. 851.)
       In adopting the provision regarding the Rental Board’s
composition, the voters of Pasadena had a rational basis to treat
Tenants without a Material Interest in Rental Property
differently from those who do not fit both specifications. In
enacting Measure H, the voters found that tenants occupied a
significant majority (57.7 percent) of housing in Pasadena and
faced greater risks and consequences of housing instability,
homelessness, and unregulated evictions. (§ 1802(a), (e)-(j), (o),
(p).) Reserving seven of 11 seats (or 63.6 percent) of the Rental
Board for Tenants without a Material Interest in Rental Property