What is the test for determining whether a city can impose a penalty for overstaying parking meters?

Here, there is no real dispute that the City is harmed because overstaying parking meters leads to increased congestion and impedes traffic flow. Without material evidence provided by appellants to the contrary, we must afford "substantial deference to the broad authority that legislatures necessarily possess in determining the types and limits of punishments." Bajakajian , 524 U.S. at 336, 118 S.Ct. 2028 (quoting Solem v. Helm , 463 U.S. 277, 290, 103 S.Ct. 3001, 77 L.Ed.2d 637 (1983) ).

Pimentel further argues that the City has proffered no quantitative evidence

[966 F.3d 941]