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But the court squarely disagreed, finding that Manhattan Beach's zoning code "always permitted short-term, as well as long-term, residential rentals." (Id. at 148 (emphasis added).) The court explained that once the house or apartment building was built, anyone — renter or owner — could reside there for periods long or short, since the code "offer[s] no textual basis for a temporal distinction about the duration of rentals", and the term "`residence' does not imply some minimum length of occupancy" (Id. at 148-149.) In short, "[a] `residential building' is used for human habitation without regard to length of occupancy," and "[i]t is possible to reside somewhere for a night, a week, or a lifetime." (Id. at 149.) As in Keen, the Santa Ana Municipal Code authorizes "single-family residence" and "multiple family residence" uses, and these classifications place no minimum length of occupancy restriction on these residential uses. (Santa Ana Mun. Code, § 41-184 et seq.) And, just as in Keen, long-term rental of residential property is permitted under the existing Santa Ana code. And so, just in Keen, without any durational requirement for rentals in the code, there is no justification for the unfounded claim that STRs are currently forbidden. National Landscape The California Court of Appeal's decision in Keen is not an outlier in holding that STRs are a lawful residential use under existing zoning regulations. At least three state supreme courts have reached the same conclusions, holding that local zoning ordinances limiting the use of property in certain districts to "residential uses" permit STRs. (See Town of Conway a Kudrick, 175 N.H. 714 (N.H. 2023); In re Toor, 192 Vt. 259 (Vt. 2012); Landing Development Corp. a City of Myrtle Beach, 285 S.C. 216 (S.C. 1985).) These courts have correctly observed that the structures being used as STRs were indisputably "single units that include `provisions for living, sleeping, eating, cooking, and sanitation,"' and that requirements for residents to be "living as a household" or the like "refer[] to a group of individuals who live together under the same roof, regardless of duration." (Kudrick, 175 N.H. at 719; see also Toor, 192 Vt. at 265 (similar quote).) More broadly, nearly two dozen state supreme courts have addressed whether homeowners association covenants and zoning ordinances like Santa Ana's that do not specifically address STRs can nonetheless be read to prohibit or limit them. The majority of these courts have come to the same conclusion: STRs are permitted residential uses. The Proposed Prohibition Would Illegally Terminate the Existing Ability to Lawfully Use One's Property for STR The proposed prohibition would immediately disallow all STRs within the City, including those already lawfully operating. The proposed prohibition would, in effect, convert currently legal STRs into immediately illegal nonconforming uses. But terminating these legal nonconforming uses in this way would violate longstanding California law. California courts have long held that a parry may continue to use their property even though such use is nonconforming. (Hill a Manhattan Beach, 6 Cal.3d 279, 285-86 (Cal. 1971); Livingston Rock & Gravel Co. a Los Angeles County, 43 Cal.2d 121, 127 (Cal. 1954); Edmonds a Los Angeles County, 40 Cal.2d 642, 651 (Cal. 1953); E.B. Jones a City of Los Angeles, 211 Cal.304, 310-311 (Cal. 1930).) The reason is simple: immediate termination of previously lawful (and now non -conforming) uses would be of doubtful constitutionality. (Livingston Rock & Gravel 3