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Co., 43 Cal. 2d at 127; Edmonds, 40 Cal. 2d at 651.) This follows from "vested rights" principles, which provide that when a zoning ordinance changes, a property owner may have a "vested right" to continue the existing use, notwithstanding the newer zoning restriction. (City of Ukiah a County of Mendocino, 196 Cal.App. 3d 47, 56-57 (Cal. Ct. App. 1987).) The California Supreme Court's decision in Avco Community Developers, Inc. v South Coast Regional Comm'n, 17 Cal.3d 785 (Cal. 1976) is one example of this constitutional principle. There, the California Supreme Court recognized that a property owner that has incurred substantial liabilities establishing a lawful use of property has a right to continue that use despite a subsequent change in zoning law. (Id. at 791.) Santa Ana's proposed Ordinances would violate these principles. We hosts have made significant investments in our homes to offer them as STRs and thus have obtained the right to continue our STR use. The City's proposed Ordinances cannot legally withdraw those rights. The Proposed Prohibition Raises Numerous Additional Constitutional Concerns As set forth below, the proposed prohibition implicates our constitutional rights to Due Process and the Right to Contract, and affects a Taking. On these or similar grounds, as explained below, a Dallas trial court recently enjoined a near -total ban on STRs much like the one Staff has advanced here. (Dallas Short -Term Rental Alliance a City of Dallas, DC-23-16845, at 1 (Dallas Dist. Ct. Dec. 6, 2023, Temporary Injunction Order). Due Process Just as terminating our preexisting, legal nonconforming uses of private property infringes on rights under state law, discussed above, it likewise infringes our federal Due Process rights. The immediate termination of a vested, nonconforming use (which the Ordinances would cause) is a deprivation of property without due process of law. (Santa Barbara Patients' Collective Health Co-op a City of Santa Barbara, 911 F.Supp.2d 884, 893-894 (C.D. Cal. 2012); McCaslin u Monterey Park, 163 Cal.App.2d 339, 346-348 (Cal. Ct. App. 1958).) Relying on similar principles, the Dallas district court found the STR ban at issue to was likely not "rationally related to" any legitimate state interest —because it did not "deter[] nuisances" or "increase[e] affordability of housing in Dallas." (Dallas Short -Term Rental Alliance Order at 5). Takings In addition to violating our Due Process rights, the immediate termination of STRs also amounts to a regulatory taking of private property without just compensation, in violation of the California and U.S. Constitutions' Takings clauses. (U.S. Const., amend. V; Cal. Const. Art. I, § 19; see, e.g., Castner a City of Oakland, 129 Cal.App.3d 94 (Cal. Ct. App. 1982).) Under Penn Central Transportation Company v City of New York, 438 U.S. 104 (1978), courts determine whether a taking has occurred based on the economic impact of the regulation on the claimant, the extent to which the regulation interferes with distinct investment -back expectations, and the nature of the governmental action. (Id. at 124.) Here, each of these factors weighs in favor of finding a taking. First, the blanket prohibition on STRs in the City would have a drastic economic impact on STR owners because all income earned from STRs would be immediately eliminated, and property owners could lose their homes al