“Multifamily housing is often treated as if it were a quasi-public resource, for example by rent control laws. The degree to which apartments should or shouldn’t be so treated was recently addressed by a California court in Coyne v. City and County of San Francisco, which considered the limits on mitigation measures a city may impose on landlords for removing residential property from the rental market,” according to Manatt, Phelps & Phillips’ Keli Osaki and Tom Muller. When San Francisco increased the relocation assistance payments property owners must pay their tenants under the Ellis Act, the increase was challenged, the duo says.