Peace Ranch, LLC v. Rob Bonta, 93 F.4th 482

Peace Ranch LLC owns a mobilehome park, Rancho La Paz, which spans the cities of Anaheim and Fullerton in Orange County, California.
California enacted AB 978, a rent-control statute tailored to "qualified mobilehome parks" located within and governed by two or more incorporated cities and intended to address rent increases in counties with populations between 2,500,000 and 3,250,000—apparently targeting Peace Ranch specifically.
The key legal dispute is whether AB 978 applies to Peace Ranch, as Peace Ranch claims it owns two separate parks, while the state and legislature consider it a single park subject to the statute.
Peace Ranch sought declaratory and injunctive relief, claiming AB 978 is unconstitutional and that enforcement was threatened if it exceeded allowed rent increases.
The district court dismissed for lack of standing, holding the statute inapplicable if Peace Ranch is actually two parks.
On appeal, the Ninth Circuit considered whether the threat of enforcement alone, absent certainty about statutory applicability, is sufficient for pre-enforcement standing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Pre-enforcement standing standard	Peace Ranch faces a substantial threat of enforcement and must choose between compliance and risking sanctions	AG argues Peace Ranch lacks injury because it simultaneously alleges the statute does not apply	Standing turns on threat of enforcement, regardless of statute's ultimate applicability
Applicability of AB 978 to Peace Ranch	Peace Ranch preserves alternative theories: park is either a single park (subject to AB 978) or two parks (not subject)	AG says if Peace Ranch is two parks, statute doesn't apply, so no real threat/injury	Sufficient for standing if plaintiff plausibly alleges chilling effect from state's position
Injury-in-fact for pre-enforcement action	Peace Ranch conformed its conduct (curbed rent increases) to avoid state enforcement, causing economic harm	AG argues voluntary compliance with inapplicable law is not injury-in-fact	Voluntary compliance due to state threat constitutes injury-in-fact if credible threat exists
Sufficiency of AG's disavowal of enforcement	State refuses to disavow intent to enforce AB 978 against Peace Ranch	AG did not explicitly state an intent not to enforce, fueling credible threat	Lack of disavowal and targeting are enough to show substantial threat

Steffel v. Thompson, 415 U.S. 452 (a plaintiff need not break the law to challenge its constitutionality)
Babbitt v. United Farm Workers Nat’l Union, 442 U.S. 289 (pre-enforcement challenges require threatened injury from imminent enforcement)
MedImmune, Inc. v. Genentech, Inc., 549 U.S. 118 (pre-enforcement plaintiffs can sue without violating the law first)
Susan B. Anthony List v. Driehaus, 573 U.S. 149 (establishes pre-enforcement standing framework, including threat of enforcement)
Federal Election Commission v. Cruz, 596 U.S. 289 (standing can exist when credible threat of enforcement exists despite factual disputes)
Yee v. City of Escondido, 503 U.S. 519 (background on mobilehome tenancy and bargaining positions)
Thomas v. Anchorage Equal Rts. Comm’n, 220 F.3d 1134 (Ninth Circuit pre-enforcement standing test)