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I may be rented for a period of less than 30 days." Municipal Code 41-2115(h). Under the 2 Municipal Code, an individual property owner can apply to split an existing lot into two. 3 Ordinance No. NS-3013 essentially said if a property owner splits their lot, they may not rent 4 dwellings on that lot for less than 30 days. The Staff Report associated with the adoption of this 5 Ordinance No. NS-3013 made no mention of the legality of STRs in other parts of the City or on 6 non-urban split lots. 7 35. On information and belief, after continuously issuing ministerial business licenses 8 for hosts renting their property on a short-term basis and long after the temporary moratorium 9 expired, the City changed its position. Around early 2022, the City suddenly claimed that STRs 10 were prohibited based on the City's "permissive"zoning ordinance through the commencement of 11 enforcement actions against existing hosts. 12 36. The City's new position contradicted decisions by the Courts of Appeal holding 13 that permissive zoning ordinances silent on STRs, such as the City's, do not prohibit STRs. More 14 specifically, in June 2022, the California Court of Appeal considered a permissive zoning 15 ordinance from Manhattan Beach that is very similar to Santa Ana's code prior to the adoption of 16 Ordinance No. NS-3061. Manhattan Beach's ordinance permitted"single-family residential" and 17 "multi-family residential" uses, but said nothing about STRs. Keen v. City of Manhattan Beach, 18 77 Cal. App. 5th 142, 149 (2022), review den'd(June 29, 2022). As a result,people in Manhattan 19 Beach had "[f]or quite some time. . . . rented residential units in Manhattan Beach on both long- 20 and short-term bases," and "[t]he City knew about that practice[.]" Id. at 146. Then, in 2015, 21 Manhattan Beach passed an ordinance banning STRs and claimed it was merely"reiterating" the 22 City's supposedly existing "implicit" ban on STRs. Ibid. The court disagreed, finding that 23 Manhattan Beach's zoning code "always permitted short-term, as well as long-term, residential 24 rentals." Id. at 148 (emphasis added). 25 37. The Court of Appeal explained that once the house or apartment building was built, 26 anyone—renter or owner—could reside there for periods long or short, since the code "offer[s] no 27 textual basis for a temporal distinction about the duration of rentals," and the term "`residence' 28 does not imply some minimum length of occupancy." Id. at 148-149. Short-term rentals are VERTFTED PETTTTON FOR WRTT OF MANDATE 10 AND COMPLATNT