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
Original Source: https://www.courtlistener.com/opinion/10761039/cal-apartment-assn-v-city-of-pasadena/ ↗

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be treated alike.’ [Citation.] ‘At core, the requirement of equal
protection ensures that the government does not treat a group of
people unequally without some justification.’ ” (People v. Hardin
(2024) 15 Cal.5th 834, 847 (Hardin); accord, Getzels v. State Bar
of California (2025) 112 Cal.App.5th 388, 398 (Getzels).)
       “Traditionally, California courts engaged in a two-part
inquiry to determine if there has been an equal protection
violation. [Citation.] The threshold question was whether a
classification affected two or more groups ‘ “similarly situated in
all material respects” ’ in an unequal manner. [Citation.] In
Hardin, the California Supreme Court held that courts no longer
needed to ask this threshold question when the challenged
classification appears on the face of the law.” (Getzels, supra,
112 Cal.App.5th at p. 398; see Hardin, supra, 15 Cal.5th at p. 850
[“when plaintiffs challenge laws drawing distinctions between
identifiable groups or classes of persons, on the basis that the
distinctions drawn are inconsistent with equal protection, courts
no longer need to ask at the threshold whether the two groups
are similarly situated for purposes of the law in question”];
accord, Cole v. Superior Court (2024) 104 Cal.App.5th 1280, 1289
[“in Hardin, our high court . . . eliminate[d] the first step of the
[equal protection] analysis . . . when the classification appears on
the face of the law”].) The only inquiry necessary in such a case
is “ ‘whether the challenged difference in treatment is adequately
justified under the applicable standard of review.’ ” (Getzels, at
p. 398, quoting Hardin, at pp. 850-851; accord, Cole, at p. 1289.)
       In allocating seven of the Rental Board positions
exclusively to Tenants without a Material Interest in Rental
Property, Measure H distinguishes between persons who meet
these criteria and other residents of Pasadena who do not.

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