On April 20, 2026, Angel Law prevailed on its claims under the California Environmental Quality Act (CEQA) in a case brought by the Santa Ana Short-term Rental Alliance against the city of Santa Ana, challenging the city council’s adoption of an ordinance that categorically banned all types of short-term rentals in Santa Ana’s 27-square mile incorporated territory. The Orange County Superior Court (Hon. Melissa R. McCormick, Complex Civil Center) ordered the city to set aside its ordinance and proceed in accordance with CEQA.
The court’s ruling represents an important victory not only for SASTRA itself. STRs were both a critical economic lifeline for local residents and businesses, and a no less critical housing resource. Before 2024, when the city council passed the STR ordinance, there were more than 1,000 STR listings, offering well over 5,000 renters flexible housing options. STRs represented an affordable alternative to expensive hotels for lower-income families seeking to visit Santa Ana and nearby attractions like Disneyland. And they provided housing for residents facing life transitions, traveling nurses, other essential workers, students, families of patients in healthcare facilities, and families displaced because of damage to their home or needing to relocate to Orange County.
The court, in a thorough 12-page statement of decision, found that CEQA precluded the city from avoiding review and public airing of the environmental impacts of its STR ordinance. The city attempted to rely on a program environmental impact report (EIR) it had prepared for its 2022 General Plan Update, claiming that the adverse impacts of the STR ban had been reviewed in that EIR. This wasn’t so. The court agreed with SASTRA that no portion of the General Plan Update EIR expressly addressed STRs, and no substantial evidence supported the city’s contention that its later, blanket STR ban was within the scope of the General Plan Update.
The court also rebuffed a separate attempt by the city to do an end-run around the law by invoking the “Existing Facilities” exemption from CEQA for its STR ordinance. As its name suggests, this CEQA exemption applies only to existing structures. Because the ordinance banned STRs from both existing and yet-to-be-built dwellings, the court rightfully concluded that the Existing Facilities exemption does not insulate the ordinance from environmental review.
The city’s 2024 STR ban was a radical and economically painful policy shift. Renting no more than an unused bedroom to just one person for less than 30 days was forbidden. The ban applied to every dwelling in every zoning district, without exceptions. It criminalized hosted and unhosted STRs alike, as well as advertising a STR on an online platform, and granted the City Attorney broad discretion to prosecute violations as a misdemeanor.
The Angel Law litigation team included Frank P. Angel and Cassandra Vo.