Can a plaintiff make a claim for sexual discrimination under the Unruh Act merely by alleging a policy's disproportionate impact upon women?

By finding the "three-times-rent" requirement reasonable, the trial court's judgment eliminated those portions of plaintiffs' complaint that challenged the requirement's specific impact on women. Thus, the court below never decided whether a plaintiff could state a claim for sexual discrimination under the Unruh Act merely by alleging a policy's disproportionate impact upon women. ²⁰ The matter appears as an issue of first impression. We must uphold the judgment on a demurrer if, under any legal theory, a cause of action is not stated. (See, e.g., Hogen v. Valley

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