In College Area Renters & Landlord Ass'n v. City of San Diego, 43 Cal. App. 4th 677 (Cal. Ct. App. 1996), a California court invalidated on state equal protection grounds a zoning ordinance that limited the number of occupants in non-owner-occupied residences while placing no occupancy limit on owner-occupied residences in the same neighborhood, where the asserted goal was to reduce overcrowding. Id. at 521. The court concluded that there was not "a sufficient relationship between the non-owner-occupied classification and the overcrowding problem" because owner occupants were just as likely as renters to contribute to overcrowding. Id. The court invalidated, on equal protection grounds, an ordinance that distinguished between tenant-occupants and owner-occupants of detached dwellings in single-family residential neighborhoods. The ordinance was designed to address nuisance problems associated with non-owner-occupied rentals, including overcrowding, lack of parking, excessive noise, and inadequate maintenance "which adversely affects the character of one-family residential zones." (Id. at p. 680.) It regulated the number of persons over age 18 who could live in a non-owner-occupied residence based on square footage, number of bathrooms and parking facilities, but no such occupancy restriction applied to owner-residents. (Id. at p. 681.) The court could "perceive of no justification for making a distinction between the two types of detached dwelling residents," and said that if the city wanted to address problems associated with overcrowded detached homes, it should do so with a law applying evenly to all households. (Id. at p. 687.)