The City of Newark had a rent control ordinance that had a cap of six percent annual rent increase unless a higher increase was justified. The Council of Newark (D) passed amendments stating that no increase could exceed twenty-five percent in one year. Cromwell Associates (P), who had already received permission for a higher rent, challenged the constitutionality of this rent control because it placed limits on annual rent increases. P claimed that he was denied a fair market rate of return and that the Constitution required regulation to serve a public purpose without being arbitrary or discriminatory.