People's Advocate, Inc. v. Superior Court

In People's Advocate, Inc. v. Superior Court (1986) 181 Cal.App.3d 316, the Court invalidated, inter alia, a portion of the Legislative Reform Act of 1983, a statutory initiative, which limited the amount of monies that the Legislature could appropriate for its own support. The Court found the limitation, which was based on a formula tied to the budget bill enacted for the budget year 1982-1983, violated the established principles that legislative enactments may not be used to divest the Legislature of the power to enact legislation within its competence and that the Legislature may not bind its own hands or those of future Legislatures by rules that are not capable of change. (181 Cal.App.3d at p. 328.) The people's initiative power was circumscribed by the same principles. (Ibid.) The Court also concluded the limitation violated article IV, section 12 of the California Constitution because it "invaded not only the content of the Governor's budget bill but displaced the process (budget and budget bill) by which the constitution commands the adoption and enforcement of the budget." (181 Cal.App.3d at p. 329.) However, the Court noted significantly that the limitation at issue "must be distinguished from the constitutional authorization to appropriate money by statute by measures other than the budget bill. That power is specifically recognized in article IV, section 12. It authorizes the Legislature and hence the people to provide by statute for a continuing appropriation to pay for some specified program. (See, e.g., Railroad Commission v. Riley (1923) 192 Cal. 54 218 P. 415.) However, the power so recognized does not authorize the placement of a legal limit upon the power of the Legislature to enact future appropriations legislation. Although as a practical fiscal matter, a statute containing a continuous appropriation may limit the Legislature's financial choices in other appropriations measures, such a limitation is not one imposed by law." (People's Advocate, supra, 181 Cal.App.3d at p. 329, fn. 13.)