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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classification drawn by the statute is rationally related to a
legitimate state interest.” ’ [Citation.] This standard—rational
basis review—‘ “is the basic and conventional standard for
reviewing economic and social welfare legislation in which there
is a ‘discrimination’ or differentiation of treatment between
classes or individuals.” ’ ” (Getzels, supra, 112 Cal.App.5th at
p. 399; accord, Gerawan Farming, Inc. v. Agricultural Labor
Relations Bd. (2017) 3 Cal.5th 1118, 1140; Warden, supra,
21 Cal.4th at p. 641.) “A court applying this standard finds ‘a
denial of equal protection only if there is no rational relationship
between a disparity in treatment and some legitimate
government purpose.’ ” (Hardin, supra, 15 Cal.5th at p. 847;
accord, Johnson v. Department of Justice (2015) 60 Cal.4th 871,
881 (Johnson); Getzels, at p. 399.)
       Petitioners do not describe themselves as members of a
suspect class or identify a fundamental right that is at stake.
Nor do petitioners even rely on equal protection cases in making
their argument that heightened scrutiny applies. Instead,
petitioners point to cases applying the balancing test developed
by the Supreme Court in Anderson v. Celebrezze (1983) 460 U.S.
780 and Burdick v. Takushi (1992) 504 U.S. 428 to consider
whether a state election law impermissibly burdens voting rights
under the First Amendment and the due process clause of the
Fourteenth Amendment. (See Anderson, at p. 787, fn. 7 [“we base
our conclusions directly on the First and Fourteenth
Amendments and do not engage in a separate Equal Protection
Clause analysis”].) Under that test, when the plaintiff is subject
to “severe” burdens on his or her voting rights because of state
action, heightened scrutiny applies such that the state law “must
be ‘narrowly drawn to advance a state interest of compelling

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