[EL] FW: CRC asks Attorney General to Change "Misleading and Inaccurate" Referendum Language
Douglas Johnson
djohnson at ndcresearch.com
Tue Aug 30 22:23:31 PDT 2011
Two key points are missing in this debate so far. Looked at in detail, these
two points reveal the extreme stretch of reality reflected in the
(taxpayer-funded) claims from the California Redistricting Commission:
1) There is no ability for the Commission to adopt "substantially similar"
(or any other) follow up legislation. The Commission's authority to draw (or
revise) plans ended on August 15th, 2011. Note the specific reference to
court-provided relief in Section 3.3(b)(3) -- if the Court sides with
plaintiffs in a claim against one or more Commission-adopted plans, the
relief suggested (though, I admit, not specifically required) is for the
Court to draw new plans. While it is theoretically possible that the Court
could ignore that suggestion and empower the Commission to make adjustments
to a plan, it seems unlikely. And that deadline means the Commission clearly
lacks the power to do so on its own (such as following a successful
referendum).
2) In a flashback to the high-profile debate a few years ago over the
definition of "is," the Commission's claims hinge on an inaccurate
definition of the word "that." [Note that the controlling language is in
Proposition 20, not Proposition 11]:
(j) If the commission does not approve a final map by at least the requisite
votes or if voters disapprove a certified final map in a referendum, the
Secretary of State shall immediately petition the California Supreme Court
for an order directing the appointment of special masters to adjust the
boundary lines of that map in accordance with the redistricting criteria and
requirements set forth in subdivisions (d), (e), and (f). [emphasis added]
The Commission claims that "of that map" is a reference to the specific
Congressional, Assembly, State Senate, or Board of Equalization map drawn by
the Commission. But the Commission incorrectly defines "that." The "of that
map" language simply differentiates among the jurisdiction covered by the
map (Congress, Assembly, State Senate or Board of Equalization). "That" is
not a reference to the specific map drawn by the Commission. The meaning of
"that" in this case is that if the Commission fails to adopt a Congressional
map, or if a referendum against a Congressional map qualifies, the Court
will step in to draw a Congressional map and only a Congressional map.
Without that provision, it is unclear that qualifying a referendum against
the Congressional map does not empower the Court to draw new Congressional,
Assembly, State Senate, and Board of Equalization districts. If you read the
language with the thought that this provision applies if the Commission
never adopts a plan for one or more of those bodies, I believe the
language's intent is clear.
And here's the trump card for this debate: the Commission's own attorney
agrees with this interpretation. Dan Kolke, one of the Commission's lead
attorneys from Gibson, Dunn & Crutcher, was a key author of Proposition 20.
He, along with other proponents of Proposition 20, have repeatedly said how
the qualification of a referendum suspends the Commission's plan and
requires a Court-drawn plan for the 2012 election.
Side note: the vote on any referended plan will be unique: the court will
have drawn an interim plan that will be in place for the 2012 election. In
effect, the voters will be choosing which plan will be used for the 2014 -
2020 elections. While the language on the ballot will be yes/no on the
Commission's plan, the real decision will be between the Commission's plan
("Yes") and keeping the Court's plan in place ("No"). That generates very
different voter decision dynamics than the usual referendum.
The Commission's filing appears to be either attorneys creatively stretching
reality with a client that is not paying attention, or a Commission ignoring
the cost to the taxpayers of its actions.
Just my two cents. Disclosure: nothing to disclose: neither the Rose
Institute, my consulting firm, or I personally am a participant in the
referendum or in any lawsuits for or against the Commission's plan, nor did
the Institute, consulting firm, or I personally work for the Commission
(though the Institute did apply, unsuccessfully, to be the Commission's
consultants, leading to a high-profile debate already familiar to many
readers of this list).
- Doug
Douglas Johnson
Fellow
Rose Institute of State and Local Government
m 310-200-2058
o 909-621-8159
douglas.johnson at cmc.edu
From: law-election-bounces at department-lists.uci.edu
[mailto:law-election-bounces at department-lists.uci.edu] On Behalf Of Fredric
Woocher
Sent: Tuesday, August 30, 2011 11:51 AM
To: David A. Holtzman; law-election at department-lists.uci.edu
Subject: Re: [EL] FW: CRC asks Attorney General to Change "Misleading and
Inaccurate" Referendum Language
David:
The "substantially similar" or "essentially different" doctrine is
judge-made, but it flows from the very notion of the referendum being a
power "reserved" to the people and thus being a "higher" authority than the
legislative power of the Legislature. The Cal Supreme Court referenced the
doctrine and some of its leading precedents in Assembly v. Deukmejian (1982)
30 Cal.3d 638, 678, which as you may know involved a referendum filed
against the Legislature's 1981 redistricting plans:
"Since its inception, the right of the people to express their collective
will through the power of the referendum has been vigilantly protected by
the courts. Thus, it has been held that legislative bodies cannot nullify
this power by voting to enact a law identical to a recently rejected
referendum measure. (See
<https://web2.westlaw.com/find/default.wl?serialnum=1949114314&tc=-1&rp=%2ff
ind%2fdefault.wl&sv=Split&rs=WLW11.07&db=661&tf=-1&findtype=Y&fn=_top&mt=Wes
tlaw&vr=2.0&pbc=C3630C7D&ordoc=1982104228> Gilbert v. Ashley (1949) 93
Cal.App.2d 414, 415-416, 209 P.2d 50; In re ***322
<https://web2.westlaw.com/find/default.wl?serialnum=1920189711&tc=-1&rp=%2ff
ind%2fdefault.wl&sv=Split&rs=WLW11.07&db=660&tf=-1&findtype=Y&fn=_top&mt=Wes
tlaw&vr=2.0&pbc=C3630C7D&ordoc=1982104228> Stratham (1920) 45 Cal.App. 436,
439-440, 187 P. 986.) Unless the new measure is "essentially different" from
the rejected provision and is enacted "not in bad faith, and not with intent
to evade the effect of the referendum petition," it is invalid. (
<https://web2.westlaw.com/find/default.wl?serialnum=1920189711&tc=-1&rp=%2ff
ind%2fdefault.wl&sv=Split&rs=WLW11.07&db=660&tf=-1&findtype=Y&fn=_top&mt=Wes
tlaw&vr=2.0&pbc=C3630C7D&ordoc=1982104228> Id., at p. 440, 187 P. 986; see
also
<https://web2.westlaw.com/find/default.wl?serialnum=1962110723&tc=-1&rp=%2ff
ind%2fdefault.wl&sv=Split&rs=WLW11.07&db=227&tf=-1&findtype=Y&fn=_top&mt=Wes
tlaw&vr=2.0&pbc=C3630C7D&ordoc=1982104228> Reagan v. City of Sausalito
(1962) 210 Cal.App.2d 618, 629-631, 26 Cal.Rptr. 775;
<https://web2.westlaw.com/find/default.wl?serialnum=1960107557&tc=-1&rp=%2ff
ind%2fdefault.wl&sv=Split&rs=WLW11.07&db=227&tf=-1&findtype=Y&fn=_top&mt=Wes
tlaw&vr=2.0&pbc=C3630C7D&ordoc=1982104228> Martin v. Smith (1959) 176
Cal.App.2d 115, 118-119, 1 Cal.Rptr. 307.) Should the referenda here be
rejected in the primary election, the Legislature will be governed by these
rules in fashioning new reapportionment plans for the remainder of this
decade."
In addition, I don't think the issue is so much what the "referendum
initiators" might have objected to or would have preferred, but what the
electorate who may ultimately pass the referendum had in mind. In that
regard, the ballot arguments and other publicized arguments of the
"initiators" are generally looked to as indicia of legislative intent and
therefore may play a role in the courts' assessment of what features should
be "essentially different" for a new measure to pass muster. But this is
really not a highly developed area of the law, and I think you raise good
questions.
I continue to disagree, however, with the implication in both your email and
in the Commission's press release and letter that there is something
meaningful to be drawn from Prop 11's directive that any maps drawn by the
court-appointed special masters must adhere to the Prop 11-enacted criteria.
Those criteria merely constitute the substantive law that governs the
redrawing of boundaries. To be sure, they must be complied with in the new
maps, but given the looseness in the joints, that does not in my view impose
significant constraints on the special masters. It certainly cannot be read
to "trump" the established law regarding referenda.
Fredric D. Woocher
Strumwasser & Woocher LLP
10940 Wilshire Blvd., Ste. 2000
Los Angeles, CA 90024
fwoocher at strumwooch.com
(310) 576-1233
_____
From: law-election-bounces at department-lists.uci.edu
[mailto:law-election-bounces at department-lists.uci.edu] On Behalf Of David A.
Holtzman
Sent: Monday, August 29, 2011 11:31 PM
To: law-election at department-lists.uci.edu
Subject: Re: [EL] FW: CRC asks Attorney General to Change "Misleading and
Inaccurate" Referendum Language
I just looked at that section (Section 9 of Article II) of the California
Constitution, and did not see a restriction precluding "substantially
similar" follow-up laws after laws are overturned by referendums. I suppose
that's in case law. If so, which cases? What were the criteria used to
assess similarity, and how were they divined?
Can the wishes of referendum instigators really constrain replacement law?
Whether or not those wishes are put to the voters as part of the referendum?
Is referendum really a twofer, providing both (1) a block against a statute
and (2) a temporary constitution-level constraint on legislative power?
Here, it looks like Prop. 11 may have trumped or limited any "no
substantially similar follow-up" rule by affirmatively requiring a follow-up
map, making the CRC map the baseline, and requiring adherence to Prop.
11-enacted criteria that are now part of the state Constitution. Post-Prop.
11, redistricting policy is no longer a wide-open playing field, as the
subject matter of other referenda may be.
The "manner" of referendum mentioned below could simply be procedure.
That's all I got from reading Section 9 of Article II.
Now, if the referendum blocks the map, what's to stop the Court from
requiring a district-less election while new district lines are being
prepared? A statewide, single transferable vote (STV), 20-winner election
would be fair. (Or make it 40 winners by STV if the Court can justify
kicking 20 State Senators out of office halfway through their terms.)
- dah
<!--[if !supportLineBreakNewLine]-->--
David A. Holtzman, M.P.H., J.D.
david at holtzmanlaw.com
On 8/29/2011 6:15 PM, Fredric Woocher wrote:
I agree with Justin as to his analysis of the second issue -- what might
occur in the interim for the next election if a referendum petition were to
qualify, but I think he and (especially) the Redistricting Commission are
giving too much deference to the boundaries that the Commission drew in the
event that the referendum were to pass and the task of redrawing the lines
were put before the Supreme Court's special masters. The whole purpose of a
referendum is for the voters to reject what the Legislature -- or in this
case, the Commission -- has enacted. Indeed, with a typical referendum, it
would be unlawful for the Legislature to respond by enacting another measure
that is substantially similar to what it had previously enacted and the
voters rejected in the referendum vote. Article XXI, section 2(i), states
that the Commission's maps "shall be subject to referendum in the same
manner that a statute is subject to referendum pursuant to Section 9 of
Article II." That would appear to mean that the same principles apply to
whatever replacement maps are to be drawn following a successful referendum
-- that is, they are not to be substantially similar to the original maps
adopted by the Commission.
The Commission's argument that the maps can only be "adjusted" by the
special masters "in accordance with the redistricting criteria requirements
set forth in subdivisions (d), (e), and (f)" also seems to place too much
weight on the last phrase. Subdivisions (d) - (f) merely set forth the
general legal requirements that apply to any and all maps that might result
from the redistricting process; there are obviously many different maps that
can comply with those requirements. For the Commission to suggest, as it
did in its press release at least, that only minor tinkering could be done
to the lines it drew because those lines were established in accordance with
the general legal criteria overstates their case. And I don't think the
mere use of the word "adjusts" would constrain a court to hew closely to the
lines drawn by the Commission, since as mentioned above, that would defeat
the very purpose of the referendum in the first place.
Typically, the proper response to a successful referendum vote would be
either to abandon the proposed legislation altogether or to amend it in a
manner that responds to the complaints of those who opposed it. Obviously,
this poses an interesting dilemma for the special masters who might be
called upon to draw new boundaries if the referendum were successful.
Obviously, they cannot abandon the effort altogether, and if the stated
objection is that the maps are too heavily weighted in favor of Democratic
partisan interests, they would be prohibited by the terms of the
Constitution from taking that into account (at least explicitly) in
re-drawing the lines. So, I'm not sure how they would or should respond.
But I don't think making only minor tinkering to the Commission's boundaries
is required, or even necessarily permitted.
In any event, I certainly don't see how the sentence in the Summary stating
that the petition will "place the revised State Senate boundaries on the
ballot and prevent them from taking effect unless approved by the voters at
the next statewide election" is misleading. That is certainly the outcome
that would result in the long term if the referendum were to qualify and be
passed by the voters.
Fredric D. Woocher
Strumwasser & Woocher LLP
10940 Wilshire Blvd., Ste. 2000
Los Angeles, CA 90024
fwoocher at strumwooch.com
(310) 576-1233
_____
From: law-election-bounces at department-lists.uci.edu
[mailto:law-election-bounces at department-lists.uci.edu] On Behalf Of Justin
Levitt
Sent: Monday, August 29, 2011 5:52 PM
To: law-election at department-lists.uci.edu
Subject: Re: [EL] FW: CRC asks Attorney General to Change "Misleading and
Inaccurate" Referendum Language
Prop 11 -- in relevant part, now in article XXI, section 2(j) of the
California Constitution -- says: "If . . . voters disapprove a certified
final map in a referendum, the Secretary of State shall immediately petition
the California Supreme Court for an order directing the appointment of
special masters to adjust the boundary lines of that map in accordance with
the redistricting criteria and requirements set forth in subdivisions (d),
(e), and (f)."
To my knowledge, neither this language nor similar language has been
construed before. But the commission's press release below seems to be
relying heavily on text: if voters disapprove the commission's map in a
referendum, the Supreme Court will adjust "that" map to arrive at a plan
going forward. To me, that confirms the commission's reading of the
baseline -- start with the Commission's lines -- if a map is voted down in a
referendum. But courts haven't had a go at the language just yet.
***
If a referendum effort gathers enough signatures, the situation between
qualifying for the ballot and the actual ballot vote is a little different.
California law is clear that once a referendum qualifies for the ballot, the
underlying law may not be put into effect until the referendum vote
(specifically, until a referendum fails). So if the referendum qualifies,
then the state Senate maps aren't legally binding.
But in that event, new elections (including filing for primaries and the
primaries themselves) will need to be conducted from some districts. There
are three options for the CA Supreme Court, which has the authority (and
responsibility) to make the decision:
1. Reverting to the last-existing lines lawfully approved -- the 2001-cycle
districts. These districts are known to be unconstitutionally
malapportioned (and likely violate the Voting Rights Act as well, given the
demographic changes of the last decade). The Supreme Court has given courts
latitude to leave unconstitutional lines in place if absolutely necessary
(Upham v. Seamon, 456 U.S. 37, 44 (1982)). But only if -- really --
absolutely necessary, as in there's not enough time to redraw lines that
would better comply. This is clearly a last-choice scenario.
2. Drawing temporary lines (governing elections at least until the
referendum vote) from scratch, following both federal law and state
constitutional requirements. It's theoretically possible that the court
would do this, following their own appointed special masters. But though it
would be straightforward to just equalize population, it's an awful lot of
work to ensure compliance with the Voting Rights Act, and with the remainder
of California's state constitutional requirements. An awful lot of work, as
the Commission just found out. So it's much more likely that the court
would spare itself the effort by ...
3. Adopting (or tweaking) the Commission's lines as the temporary lines
(governing elections at least until the referendum vote). This is by far
the most likely option, basically mirroring what happened in 1982, when the
court adopted the legislature's new lines between the filing of a referendum
and that referendum vote. (Assembly v. Deukmejian
<http://scholar.google.com/scholar_case?case=18427288310672228624> , 30 Cal.
3d 638 (1982)). This spares the court the work of attempting to draw
compliant maps, because it at least has the Commission's work product as an
attempt at legal compliance. It also is a way of reflecting the best-known
preferences of the California public, at least at the time: the public voted
for the Commission and its procedure, and the only evidence to the contrary
are the 5% of voters signing the referendum petition. That's not nothing,
but the Commission's work is still a better gauge of the majority of
California voters for the time being...
And that option #3 tells me that in the period between qualifying and the
referendum vote, the Commission's maps should be the baseline as well.
Here, there's a bit more court interpretation -- the 1982 Deukmejian
decision -- but that was before Prop 11; though the logic seems solid to me,
a different court might read Prop 11 differently.
Justin
On 8/29/2011 2:06 PM, Eric McGhee wrote:
The California Citizens Redistricting Commission has just petitioned the CA
AG to stop signature gathering for the referendum against the State Senate
maps (see below). That's interesting by itself, but as part of their
petition they're arguing that the law constrains the potential maps the CA
Supreme Court could draw as relief, should the Court end up hearing the
case. As I read it, the commission is saying that the Court is required to
treat the commission's maps as the baseline, and to adjust them only enough
to correct any legal problems that might be identified.
Can anyone on the list comment on this interpretation of the law? Is the
Court in fact constrained in this way?
Cheers,
Eric
Eric McGhee | Research Fellow | PPIC | 415-291-4439
Any opinions expressed in this message are those of the author alone and do
not necessarily reflect any position of the Public Policy Institute of
California.
From: California Citizens Redistricting Commission
[mailto:rob.wilcox at crc.ca.gov]
Sent: Monday, August 29, 2011 12:40 PM
To: Eric McGhee
Subject: CRC asks Attorney General to Change "Misleading and Inaccurate"
Referendum Language
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CRC
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Press Release
August 29, 2011
For Immediate Release
Contact: Rob Wilcox
Communications Director
916-709-6358
California Citizens Redistricting Commission
Citizens Redistricting Commission
Asks Attorney General to Change
"Misleading and Inaccurate" Language in the
Proposed Referendum on the Commission's State Senate Maps
Sacramento, CA (August 29, 2011) --
The California Citizens Redistricting Commission has asked the state's
Attorney General to correct misleading and inaccurate information contained
in a proposed referendum on the Commission's final certified State Senate
maps. The Commission has also requested the proponents of the referendum to
hold off on gathering signatures for a short period until the Attorney
General fixes the summary language. The Commission also has asked the
Secretary of State to wait for the Attorney General's revised summary before
notifying and providing copies of the summary to county election officials.
"The Summary represents a misunderstanding of Article XXI of the California
Constitution. In order to avoid misleading and confusing the voters during
the referendum process, and to avert the inevitable inefficiencies and
needless costs that would result if the referendum summary is later found to
be invalid, we respectfully request that your office revise and reissue the
Summary to accurately reflect California law," wrote the Commission's
litigation counsel George H. Brown and James Brosnahan in a letter to the
office of the state Attorney General.
The letters from the Commission point out two problems with the summary of
the proposed referendum that would be used by the proponents to gather
signatures. First, the summary states that the referendum petition, "if
signed by the required number of voters," will "[p]lace the revised State
Senate boundaries on the ballot and prevent them from taking effect unless
approved by the voters at the next statewide election." This is misleading
because even if the referendum qualifies and the voters reject the
Commission's Senate maps in the next statewide election, there is no reason
to believe that the Senate maps as drawn by the Commission will not
ultimately go into effect. In particular, the Voters First Act specifically
amended the California Constitution to provide that if voters reject the
Commission's maps in a referendum, the California Supreme Court may appoint
special masters to "adjust" the Commission's maps - not start over from a
blank slate - and only to the extent necessary to comply with the
redistricting criteria set forth in the Constitution. But the Commission
scrupulously adhered to these criteria when drawing the maps in the first
instance. Accordingly, even if the voters ultimately reject the Commission's
Senate maps, the California Supreme Court would be required to allow all of
the maps to become effective, unless special masters found specific
instances of non-compliance with the redistricting criteria.
Second, the Attorney General's summary states that a referendum petition
successfully filed with the Secretary of State will "[r]equire
court-appointed officials to set interim boundaries for use in the next
statewide election." This is wrong. Even if the California Supreme Court
exercised its discretion to hear an action concerning interim boundaries for
the next election (which is by no means certain), there is no requirement
for the Court to appoint special masters or any other officials to assist in
this task. More important, there would be no requirement for the Court to
"set" boundaries that were any different from the Commission's Senate maps.
To the contrary, in analogous circumstances, the California Supreme Court in
1982 allowed the newly drawn maps to apply in the next election, even though
a referendum had already qualified and was to be voted on in that same
election.
For these reasons, the Commission believes that the summary of the proposed
referendum is misleading, fails to reflect California law, and brings
needless uncertainty to the referendum process. The Commission hopes that
the Attorney General will take these issues into account and will promptly
revise the summary, and that the proponents refrain from collecting
signatures from voters using a misleading petition, which would ultimately
prove to be a waste of time and effort.
The Commission's letters to the Attorney General, the referendum's
proponents and the Secretary of State can be found at the Commission's
website at www.wedrawthelines.ca.gov
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Justin Levitt
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Loyola Law School | Los Angeles
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justin.levitt at lls.edu
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