In Kopp v. Fair Pol. Practices Com. (1995) 11 Cal.4th 607, the California Supreme Court extensively reconsidered the power of courts to "reform" or rewrite statutes and initiatives. (Id. at pp. 626-663.) The court concluded that "a court may reform -- i.e., 'rewrite' -- a statute in order to preserve it against invalidation under the Constitution, when we can say with confidence that (i) it is possible to reform the statute in a manner that closely effectuates policy judgments clearly articulated by the enacting body, and (ii) the enacting body would have preferred the reformed construction to invalidation of the statute. By applying these factors, courts may steer clear of 'judicial policymaking' in the guise of statutory reformation, and thereby avoid encroaching on the legislative function in violation of the separation of powers doctrine." (Id. at pp. 660-661.)