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Cal. Apartment Assn. v. City of Pasadena (2025)

Citation
Cal. Apartment Assn. v. City of Pasadena (2025)
Parent Document
Cal. Apartment Assn. v. City of Pasadena (2025)
Jurisdiction
California (state)
Effective Date
2025-12-18

Other Sections in This Document (114)

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11
streamlining.” (Clark v. Patterson (1977) 68 Cal.App.3d 329, 335,
fn. 6.) By that point, the Supreme Court had already
distinguished between the terms “amendment” and “revision” in
the context of changes to the Constitution. (See McFadden,
supra, 32 Cal.2d at pp. 331-334; Livermore v. Waite (1894)
102 Cal. 113, 117-119.) “When a term has been given a
particular meaning by a judicial decision, it should be presumed
to have the same meaning in later-enacted statutes or
constitutional provisions.” (Richmond v. Shasta Community
Services Dist. (2004) 32 Cal.4th 409, 422-423.) Moreover, because
article XI distinguishes charter amendments and revisions in the
same manner that constitutional amendments and revisions are
distinguished under articles II and XVIII, we conclude the
amendment-revision framework that courts have developed to
assess whether a proposed change to the Constitution is an
amendment or a revision may fairly be applied to determine if a
local initiative such a Measure H constitutes a permissible
amendment or an impermissible revision to a municipal charter. 4