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
Original Source: https://www.courtlistener.com/opinion/10761039/cal-apartment-assn-v-city-of-pasadena/ ↗

Full Text

1,854 chars

14
       3.    Quantitative effect
       The quantitative analysis in the amendment-revision
inquiry has become “less significant” since the Constitution’s
single-subject rule was adopted in 1948. (Weber, supra,
16 Cal.5th at p. 259; see Cal. Const., art. II, § 8, subd. (d) [“An
initiative measure embracing more than one subject may not be
submitted to the electors or have any effect.”]; see also Shea
Homes Limited Partnership v. County of Alameda (2003)
110 Cal.App.4th 1246, 1255 [single-subject rule applies as
limitation to statewide and local initiatives].) Before that rule’s
adoption, the Supreme Court determined a proposed initiative in
McFadden was an impermissible revision because its effect
“would be to substantially alter the purpose and to attain
objectives clearly beyond the lines of the Constitution as now
cast” rather than working “ ‘within the lines of the original
instrument’ ” to achieve “ ‘an improvement or better carry out the
purpose for which it was framed.’ ” (McFadden, supra, 32 Cal.2d
at p. 350.) The initiative in McFadden proposed to add 21,000
words to a then-55,000-word Constitution and dealt with a “wide
and diverse range of subject matters,” including retirement
pensions, gambling, taxes, healing arts, civic centers, surface
mining, fishing, city budgets, liquor control, senate
reapportionment, and oleomargarine. (Id. at pp. 334-345.) The
court determined the initiative would repeal or substantially
alter “at least 15 of the 25 articles” contained in the Constitution
at the time, introduce at least four new topics to the Constitution,
and “substantially curtail[]” the legislative and judicial functions
of the state government. (Id. at p. 345.) The court emphasized
that the “far reaching” initiative was also “multifarious” in its
construction in that it denied the electorate “an opportunity to

Other Sections in This Document (114)

Full Text