Veterans' Fin.Comm. of 1943 v. Betts

In Veterans' Fin.Comm. of 1943 v. Betts, 55 Cal. 2d 397, 11 Cal. Rptr. 103, 359 P.2d 471 (Cal. 1961), the Legislature called a special election, but the Governor failed to issue a proclamation. Id. at 472-73. The California Supreme Court indicated that the requirement of a proclamation was intended to "inform the electors" of the offices to be filled and the measures to be voted upon. Id. at 473-74. The court held that because the time, place, and measures to be voted upon in the special election were prescribed by law, and the electors are presumed to know the law, the proclamation was not necessary to the validity of the election. Id. at 474. In other words, a special election can be initiated by an authorized party other than the Governor, and the requirement that the Governor shall issue a proclamation of the special election is a notice provision, and not necessarily a prerequisite to a valid special election.