 In "Palmer/Sixth Street Properties LP v. City of Los Angeles" (2009), the issue involved how to apply Costa–Hawkins to an inclusionary housing ordinance of the City of Los Angeles.Inclusionary housing laws (also called inclusionary zoning) apply to the construction of new multi-unit developments and seek to mandate the inclusion of some affordable units with price controls, along with a larger number of units to be sold on the free market.About one-third of California cities and counties have inclusionary zoning ordinances.