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C060441
COURT OF APPEAL OF THE STATE OF CALIFORNIATHIRD APPELLATE DISTRICT
H
OWARD
J
ARVIS
T
AXPAYERS
A
SSOCIATION
,
 
 ET AL
 .
,
Petitioners and Appellants,
v.
D
EBRA
B
OWEN
,
 
S
ECRETARY OF
S
TATE
,
 
 ET AL
 .
,
 Respondents and Respondents
.Appeal from a Judgment by the Superior Court, Sacramento CountyCase No. 34-2008-80000048-CU-WM-GDS, Hon. Michael P. Kenny
APPELLANTS’ OPENING BRIEF
Trevor A. Grimm, SBN 34258Jonathan M. Coupal, SBN 107815Timothy A. Bittle, SBN 112300Howard Jarvis Taxpayers Foundation921 Eleventh Street, Suite 1201Sacramento, CA 95814Telephone:(916) 444-9950Facsimile:(916) 444-9823
 Attorneys for Appellants
 
1
RULE 8.204(a)(2) STATEMENT
This case of first impression avers that when the State Legislature is theproponent of a measure on the ballot, it has a conflict of interest which, underarticle II, §§ 3 and 4 of the state constitution, disqualifies it from preparing theimpartial descriptions and analyses for the voters. In this case, the Legislaturewrote the ballot label, title and summary for Proposition 1A, the high-speedrail bond, on the November 2008 statewide ballot.This action was brought as an election writ during the measure’sspecially shortened 8-day public examination period. Petitioners sought anorder that the Legislature, being prohibited from drafting the analyses for itsown measure, must allow the Attorney General, or assign someone else whois impartial, to write the ballot label, title and summary.After an expedited hearing, the Judge, applying a deferential standardof review, ordered certain false statements corrected in the Legislature’s ballotmaterials, but ruled against petitioners on the larger question of whether theLegislature is allowed to write the ballot materials. Judgment was entered onSeptember 3, 2008. Petitioners timely appealed. The judgment is now final.
ISSUES ON APPEAL
1.Under article II, §§ 3 and 4, is it constitutionally permissible forthe Legislature, when it is the proponent of a measure, to dictate the wordingof the impartial information that the voters will see for that measure?2.If so, should the standard of judicial review for that wording behigher than the deferential standard applied by the Superior Court?
STATEMENT OF FACTS
In the waning hours of the 2008 legislative session, AB 3034 wasgutted, amended, and jammed through an abbreviated hearing and concurrenceprocess to place Proposition 1A on the November 4, 2008, ballot.
See
BillHistory, Clerk’s Transcript (“CT”) at 121.
 
1
AB 3034 appears in its last-amended bill form, rather than chapter form(which lacks line numbers), for ease of citation.
2Proposition 1A was a $9.95 billion bond proposal to provide seedmoney for the construction of high-speed rail lines on one or more optionalroutes listed in the measure.
See
AB 3034, CT at 85:30.
1
Ordinarily, the Attorney General prepares an impartial ballot label, andballot title and summary for any statewide measure presented to the voters,including any measure presented by the Legislature. Elec. Code §§ 9051,9086, 13280, 13281; Gov. Code § 88002.In the rare case where the Attorney General has a conflict of interestbecause he authored the measure, Legislative Counsel assumes responsibilityfor preparing the impartial ballot label, title and summary. Elec. Code § 9003.In the bill placing Proposition 1A on the ballot, the Legislature wroteits own ballot label, title and summary, and “notwithstanding any otherprovision of law,” prohibited the Attorney General from revising them orpreparing his own. The bill also required the Secretary of State “not-withstanding any other provision of law,” to print in the ballot only what theLegislature had written. CT at 98:33, 99:12, 99:26, and 100:13.According to the evidence before the Superior Court, this phenomenonof the Legislature supplanting the Attorney General’s impartial analyses wasunprecedented in California’s long electoral history until quite recently. TheLegislature wrote the title and summary for a tax increase, Proposition 111, onthe June 1990 ballot.
See
Stats 1989, ch. 106, CT at 170. Another fourteenyears passed, and then the practice exploded. The Legislature wrote the ballotlabel, and the title and summary for a bond to balance the state budget,Proposition 57, on the March 2004 ballot.
See
Stats 2003, ch. 2, CT at 167.In the next statewide election cycle, the Legislature placed three bondproposals, Propositions 1B, 1C, and 1D, on the November 2006 ballot and
of 00

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