In Nash v. City of Santa Monica (1984) 37 Cal.3d 97, the California Supreme Court reviewed a section of the City's charter which required landlords to obtain a permit from the rent control board before removing rental units from the housing market--a permit which the landlord could only get by showing that rental use would not earn a fair return on investment, and that removal would not displace low- or moderate-income persons, and that removal would not adversely affect the City's supply of housing. The California Supreme Court found the ordinance constitutional. (Id. at p. 101)