Thanks to everyone for the input. My last car was a 2001 Toyota Avalon, which got about 21 mpg. I mostly drive in the city (San Francisco, up and down hills, frequent stops and starts), very short trips (15 minutes or so average). My TCH has had significantly better mileage on my few longer highway trips.

When I questioned whether there was "false advertising" it was specifically because Toyota's billboards claiming 40 mpg city are throughout the city of San Francisco, and "Any City" certainly implies San Francisco is included. This motivated me to get my car, and to now learn I won't have a prayer of anything close to that mileage in this city makes me feel misled.