Billig v. Voges

In Billig v. Voges (1990) 223 Cal. App. 3d 962, the appellants argued that they had satisfied the full text requirement by attaching the city's published summary of an ordinance to a referendum petition. The Billig court reasoned that "a summary of a proposed ordinance is a mere notification of a prospective law which gives voters the opportunity to inquire further. On the other hand, because a referendum petition asks electors to make a decision about their acceptance or nonacceptance of a proposed ordinance, it requires that voters be fully informed of the substance of the challenged measure so that the petition reflects the actual, informed will of the people." (Billig, supra, 223 Cal. App. 3d at page 967.)