Kenneth Rosen asks whether multifamily is still in extra innings, or already playing a new game

Forty-one symposiums in, Ken Rosen is still asking the room what inning it is.

Rosen has directed UC Berkeley's Fisher Center for Real Estate and Urban Economics for more than four decades, and the Fisher Center's Annual Real Estate and Economics Symposium hit its 41st edition in 2025. His signature image for this stretch of the market, quoted in Haas News in 2024, is that real estate is in "extra innings": a cycle that has run past its normal recovery clock, still the same game, everyone waiting on a walk-off that keeps not coming. It is a good metaphor, which is exactly why it deserves pressure. Extra innings assumes the rulebook held. Same field and same umpires, just a longer game.

I spent this week inside two multifamily case files that test that assumption, and I want to write them up the way they actually read from the ground.

Field note one, Minneapolis

Minneapolis adopted its citywide 2040 Plan on December 7, 2018, ending single-family-only zoning across the city, with triplexes allowed on every lot and up to six-plus units along transit corridors. The implementing zoning took effect in January 2020. Then the game stopped being about zoning at all. Environmental plaintiffs, with the Audubon Chapter of Minneapolis among them, sued under the Minnesota Environmental Rights Act, arguing the plan needed a full environmental impact statement. In 2022 a Hennepin County judge enjoined the plan. In September 2023 the Court of Appeals upheld the injunction. On May 13, 2024, the Court of Appeals reversed itself and lifted it. Six days later, on May 19, the Minnesota Legislature passed the Comp Plan Clarity Act and codified the exemption. In August 2024 the Minnesota Supreme Court declined review.

Count it. From adoption to legally settled: five years and eight months. Our case file calls Minneapolis 2040 the most legally tested municipal upzoning in America, and the production numbers on the other side of that gauntlet are the reason everyone still fights about it. Jason Ward's RAND analysis found Minneapolis multifamily permitting ran about 12% above peer cities through 2023, while rents grew roughly 1% against 14% regionally. The policy survived and the data vindicated it.

But notice what actually ended the fight. Not the appellate reversal. The legislature. A state body reached onto the field mid-litigation and changed what the environmental statute could be used to do. That is not a longer game.

That is a rule change.

Field note two, Del Mar

Del Mar, California, seven acres of oceanfront bluff at 929 Border Avenue. In 2022 a developer proposed 259 build-to-rent units there, 85 of them deed-restricted affordable, a project our case file notes would satisfy the city's entire state-assigned housing obligation in one swing. The city never denied it. Denial would create an appeal. Instead, Del Mar deemed the application incomplete. Then deemed the second version incomplete. Then the third, each round demanding new coastal-program studies and bluff-stability analyses, with view-corridor requests stacked on top. An incompleteness determination that never ends is a denial that never has to be appealed, and our file scores the resulting posture 42 out of 100 with more than three years elapsed and zero units built.

What broke the loop was not the developer's lawsuit, though one was filed. It was Sacramento. In December 2025, Attorney General Rob Bonta warned Del Mar of penalties. In February 2026 his office issued a formal Housing Accountability Act violation letter. As of our file, no building permit exists and the enforcement process continues, so I will not pretend to know the ending. The structural fact is enough: a coastal city ran a paperwork siege for three-plus years, and the actor that finally imposed a cost was the state's top law-enforcement office.

Extra innings has no move like that in it. Umpires do not get replaced in the tenth.

The answer to Rosen's question

So, still in extra innings, or a new game? Here is my read, offered as a read and not a hedge. On capital-markets time, Rosen is broadly right; rates, values, and transaction volume are behaving like a cycle that ran long. But multifamily's binding constraint stopped being capital-markets time somewhere around 2022. The constraint is entitlement time, and on entitlement time the sport itself changed. Minneapolis needed 68 months to make one upzoning stick, and only a legislature could close it out. Del Mar's clock has run well past three years without producing so much as an appealable no, and only an attorney general moved it. In both files, the decisive actor is one the old game's scorecard did not track: the state, overruling the local umpire in real time.

A market where towns call balls and strikes is one game. A market where the state can eject the umpire mid-count is a different one, with different winners. In the old game, the skill was local, the relationships and the patience to work a council. In the new one, the skill is knowing which statute is loaded before you swing, because Fairfax-style ministerial paths, 40B overrides, Builder's Remedy filings, and AG enforcement letters are now where the runs actually score.

My bet, falsifiable on two clocks: Del Mar's application reaches a completeness determination within twelve months of the February 2026 violation letter, and by the Fisher Center's 45th symposium the entitlement-time story, state versus town, will headline the multifamily panel in place of the innings count. Rosen taught this industry to ask what inning it is. The better 2026 question is who is umpiring, and the answer has already changed on the public record, whether or not the crowd has noticed.

Check the box score in twelve months. If Del Mar is still deemed incomplete, I owe Rosen an apology and the old game another season.