in gender-discrimination cases.” As we have discussed, Lingle did not create a new substantive due process test for property rights-based claims. Given the Supreme Court’s consistent warning that courts should avoid creating new substantive due process rights, we will follow our existing precedent, rather than create a new level of scrutiny. See, e.g., Chavez v. Martinez, 538 U.S. 760, 776, 123 S.Ct. 1994, 2006, 155 L.Ed.2d 984 (2003) (noting its “oft-stated reluctance to expand the doctrine of substantive due process”). After Lingle other Circuit Courts have also applied a version of rational basis scrutiny, rather than a higher “substantial advancement test” like that proposed by plaintiffs here. See, e.g., Samson v. City of Bainbridge Island, 683 F.3d 1051, 1058 (9th Cir.2012) (<HOLDING>); A Helping Hand, LLC, 515 F.3d at 372-73
holding that a zoning ordinance impinging upon a landowners desired use of his property does not offend substantive due process norms so long as the regulation is not clearly arbitrary and unreasonable having no substantial relation to the public health safety morals or general welfare holding that the burden of overcoming a zoning ordinances presumption of validity is satisfied when it is shown that the ordinance does not bear a substantial relation to the public health safety morals or general welfare holding that mere neglect for prisoners safety does not amount to a substantive due process violation implying that intent to do harm would be an abuse of government power and amount to a substantive due process violation holding that to establish a substantive due process violation the samsons must show that bainbridges ordinances establishing and extending the moratorium were clearly arbitrary and unreasonable having no substantial relation to the public health safety morals or general welfare quotation marks omitted holding that to establish a violation of due process an alien must show that she was denied a full and fair opportunity to present her claims internal quotation marks omitted