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S174540
IN THE SUPREME COURT OF CALIFORNIA
CHARLES YOUNG.
 Petitioner,
v.
GREGORY SCHMIDT. Secretary of the California Senate, et al.,
 Respondents.
Pending a Request for Original Jurisdiction
APPLICATION FOR LEAVE TO FILE, ANDCOMPLAINT IN INTERVENTION OF HOWARDJARVIS TAXPAYERS ASSOCIATION
TREVOR A. GRIMM, SBN 34258JONATHAN M. COUPAL SBN 107815TIMOTHY A. BITTLE, SBN 112300Howard Jarvis Taxpayers Foundation921 Eleventh Street, Suite 1201Sacramento, CA 95814(916) 444-9950Attorneys for Intervener,Howard Jarvis Taxpayers Association
 
APPLICATION FOR LEAVE TO FILECOMPLAINT IN INTERVENTION
By this application, Howard Jarvis Taxpayers Association ("HJTA")seeks leave pursuant to Code of Civil Procedure section 387 to file the attachedComplaint in Intervention. Leave to intervene is requested on the grounds thatHJTA has a direct interest in the subject matter that will be decided by thisaction, and that its interest is not adequately represented by the existing parties.ARGUMENTITHE COURT SHOULD ALLOW INTERVENTIONCode of Civil Procedure section 387 authorizes any person who has aninterest in the matter in litigation, or in the success of either of the parties, uponleave of court, to intervene in the action and become a party if "the disposition of the action may as a practical matter impair or impede that person's ability to protect that interest, unless that person's interest is adequately represented byexisting parties."The late Howard Jarvis, founder of HJTA, and Paul Gann, whose CitizensCommittee later merged with HJTA, were the authors and sponsors of Proposition 13, which added article XIII A to the California Constitution. Thesemen, and literally thousands of volunteers who are still members of HJTA,gathered the signatures needed to qualify Proposition 13 for the statewide ballot,and contributed their time and money to campaign for its passage. HJTA is theorganization Mr. Jarvis formed to continue defending Proposition 13 after hisdemise. In addition, HJTA has over 200,000 taxpayer members who personally benefit from the tax reductions achieved by Proposition 13. On behalf of bothitself and its members, then, HJTA
1
 
has a direct interest in the validity of Proposition 13, which is one of thetwo constitutional provisions targeted by this lawsuit.The present action challenges article
XIII
A, section 3, the section of Proposition 13 that requires a two-thirds vote of both houses of the Legislature toincrease state taxes. This Court has described the various sections of Propositionas "interrelated and interdependent, forming an interlocking 'package' deemednecessary by the initiative's framers to assure effective real property tax relief."
 Amador Valley Joint Union High Sch. Dist. v. State Bd. of Equalization
(1978) 22Ca1.3d 208, 231. Thus, a threat to section 3 is a threat to Proposition 13 as awhole, for "any tax savings resulting from the operation of sections 1 and 2 could be withdrawn or depleted by additional or increased state ... levies of other than property taxes."
 Amador Valley,
22 Ca1.3d at 231.HJTA and its members also have an interest in defending article
IV,
section 12(d), the other provision attacked by this lawsuit. For over 75 years,article
IV,
section 12(d) has required a two-thirds vote of both houses of theLegislature to pass a state budget. HJTA believes that the easiest way to controlthe growth of taxes is to control the growth of new spending in the budget process. The two-thirds vote requirement ensures that new spending will beapproved only when there is a high degree of consensus regarding its necessity.The respondents named in this action are the Secretary of the StateSenate and the Chief Clerk of the State Assembly. In their official capacities,neither has any rights at stake. To the extent they have any interest in the case atall, as employees of the Legislature who serve at the pleasure of the majority party, they are naturally aligned with the position of petitioner Young, who wantsthe majority party to be able to unilaterally2
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