In San Francisco v. Dunn (1886) 69 Cal. 73, the California Supreme Court addressed former article IV, section 22 of the state Constitution. 3 This section stated that "no money shall be drawn from the Treasury but in consequence of appropriation made by law, and upon warrants duly drawn thereon by the Controller," but permitted the Legislature, "notwithstanding anything contained" in the Constitution, to grant aid to counties, cities, towns, and private entities that supported orphans, with the proviso that enumerated counties, cities and towns that supported orphans were entitled to "the same pro rata appropriations as may be granted to such institutions under church, or other control." In San Francisco, the City and County of San Francisco sought a writ of mandate directing the state Controller to disburse the pro rata allocation of aid accorded to them under California Constitution, former section 22 of article IV. ( San Francisco v. Dunn, supra, 69 Cal. at p. 74.) Observing that the Legislature had granted aid to private institutions within San Francisco, the court in San Francisco held that the writ was properly granted, reasoning that "such appropriation having been made, the ... proviso in former article IV, section 22 became self-executing as to counties, cities and counties, cities, and towns; and no further legislative action was required." ( 69 Cal. at p. 74.)