OPINION
PREGERSON, Circuit Judge:
This case involves a constitutional challenge to the defendant City of Los Angeles's ("City") Rent Escrow Account Program ("REAP"). REAP is an administrative program codified in the Los Angeles Municipal Code ("LAMC"). The Los Angeles Housing Department ("Housing Department") places property into REAP when a landlord fails to repair habitability violations. See Housing Department Rent Adjustment Commission Regulations...
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