single-subject rule in California

2024(Briggs, supra, 3 Cal.5th at p. 829 , italics omitted; One Technologies, supra, at p. 760.) Yet the common purpose to which the initiative’s various provisions relate cannot be “ ‘so broad that 12 a virtually unlimited array of provisions could be considered germane,’ ” which would “ ‘essentially obliterat[e] the constitutional requirement.’ ” (Senate of the State of Cal. v. Jones, supra, 21 Cal.4th at p. 1162 ; Brosnahan v. Brown (1982) 32 Cal.3d 236, 253 [rule “forbids joining disparate provisions which [are] germane only to topics of excessive generality such as ‘government’ or ‘public welf

2024(Briggs, supra, 3 Cal.5th at p. 829 , italics omitted; One Technologies, supra, at p. 760.) Yet the common purpose to which the initiative’s various provisions relate cannot be “ ‘so broad that 12 a virtually unlimited array of provisions could be considered germane,’ ” which would “ ‘essentially obliterat[e] the constitutional requirement.’ ” (Senate of the State of Cal. v. Jones, supra, 21 Cal.4th at p. 1162 ; Brosnahan v. Brown (1982) 32 Cal.3d 236, 253 [rule “forbids joining disparate provisions which [are] germane only to topics of excessive generality such as ‘government’ or ‘public welf

2024(Briggs, supra, 3 Cal.5th at p. 829 , italics omitted; One Technologies, supra, at p. 760.) Yet the common purpose to which the initiative’s various provisions relate cannot be “ ‘so broad that 12 a virtually unlimited array of provisions could be considered germane,’ ” which would “ ‘essentially obliterat[e] the constitutional requirement.’ ” (Senate of the State of Cal. v. Jones, supra, 21 Cal.4th at p. 1162 ; Brosnahan v. Brown (1982) 32 Cal.3d 236, 253 [rule “forbids joining disparate provisions which [are] germane only to topics of excessive generality such as ‘government’ or ‘public welf

2024(Briggs, supra, 3 Cal.5th at p. 829 , italics omitted; One Technologies, supra, at p. 760.) Yet the common purpose to which the initiative’s various provisions relate cannot be “ ‘so broad that 12 a virtually unlimited array of provisions could be considered germane,’ ” which would “ ‘essentially obliterat[e] the constitutional requirement.’ ” (Senate of the State of Cal. v. Jones, supra, 21 Cal.4th at p. 1162 ; Brosnahan v. Brown (1982) 32 Cal.3d 236, 253 [rule “forbids joining disparate provisions which [are] germane only to topics of excessive generality such as ‘government’ or ‘public welf

2006(See, e.g., Eu, supra, 54 Cal.3d at pp. 512-514, 286 Cal.Rptr. 283 , 816 P.2d 1309 ; Brosnahan, supra, 32 Cal.3d at pp. 245-253, 186 Cal.Rptr. 30 , 651 P.2d 274 ; Fair Political Practices Commission, supra, 25 Cal.3d 33, 38-43 , 157 Cal.Rptr. 855 , 599 P.2d 46 ; see also Jones, supra, 21 Cal.4th at p. 1158 , 90 Cal.Rptr.2d 810 , 988 P.2d 1089 ["The single-subject rule . . . simply precludes drafters from combining, in a single [measure], provisions that are not reasonably germane to a common theme or purpose" (italics omitted)].) The governing decisions' consistent application of the standard

2006(See, e.g., Eu, supra, 54 Cal.3d at pp. 512-514, 286 Cal.Rptr. 283 , 816 P.2d 1309 ; Brosnahan, supra, 32 Cal.3d at pp. 245-253, 186 Cal.Rptr. 30 , 651 P.2d 274 ; Fair Political Practices Commission, supra, 25 Cal.3d 33, 38-43 , 157 Cal.Rptr. 855 , 599 P.2d 46 ; see also Jones, supra, 21 Cal.4th at p. 1158 , 90 Cal.Rptr.2d 810 , 988 P.2d 1089 ["The single-subject rule . . . simply precludes drafters from combining, in a single [measure], provisions that are not reasonably germane to a common theme or purpose" (italics omitted)].) The governing decisions' consistent application of the standard

2024(Senate of the State of Cal. v. Jones (1999) 21 Cal.4th 1142, 1156 .) However, because “ ‘the initiative process occupies an important and favored status in the California constitutional scheme,’ ” the rule “ ‘should not be interpreted in an unduly narrow or restrictive fashion that would preclude the use of the initiative process to accomplish comprehensive, broad-based reform in a particular area of public concern.’ ” (Briggs v. Brown (2017) 3 Cal.5th 808, 828 (Briggs).) There are two tests for measuring compliance with the single-subject rule.

2024(Briggs, supra, 3 Cal.5th at p. 829 , italics omitted; One Technologies, supra, at p. 760.) Yet the common purpose to which the initiative’s various provisions relate cannot be “ ‘so broad that 12 a virtually unlimited array of provisions could be considered germane,’ ” which would “ ‘essentially obliterat[e] the constitutional requirement.’ ” (Senate of the State of Cal. v. Jones, supra, 21 Cal.4th at p. 1162 ; Brosnahan v. Brown (1982) 32 Cal.3d 236, 253 [rule “forbids joining disparate provisions which [are] germane only to topics of excessive generality such as ‘government’ or ‘public welf

2023Dist. v. State Bd. of Equalization (1978) 22 Cal.3d 208, 231 .) Because “the initiative process occupies an important and favored status in the California constitutional scheme,” “the single-subject requirement should not be interpreted in an unduly narrow or restrictive fashion that would preclude the use of the initiative process to accomplish comprehensive, broad- based reform in a particular area of public concern.” (Briggs v. Brown (2017) 3 Cal.5th 808, 828 (Briggs).) “ ‘ “[T]he Constitution’s initiative and referendum provisions should be liberally construed to maintain maximum power in

2007(Amador, supra, 22 Cal.3d at p. 231 ; see Shea Homes Limited Partnership v. County of Alameda (2003) 110 Cal.App.4th 1246, 1257 [ 2 Cal.Rptr.3d 739 ].) The Council next argues that the provisions added to the Health and Safety Code by Proposition 71 run afoul of the single-subject rule because the Cures Act “revises the application of conflicts of interest laws and specifically seeks to exempt the members of the ICOC from their conflicts of interest.” The manner in which the Act qualifies and clarifies conflict of interest restrictions for members of the ICOC is described, post, at pages 1366

2024(See People v. Frierson (1979) 25 Cal.3d 142 , 186–187; Brosnahan v. Brown (1982) 32 Cal.3d 236 , 260–261; In re Lance W. (1985) 37 Cal.3d 873 , 891–892; Raven v. Deukmejian (1990) 52 Cal.3d 336 , 349–355 (Raven); Legislature v. Eu, supra, 54 Cal.3d at pp. 506–512; Professional Engineers in California Government v. Kempton (2007) 40 Cal.4th 1016 , 1046–1047; Strauss, supra, 46 Cal.4th at pp. 440– 457.) The quantitative aspect of the inquiry has become less significant since the adoption of the single-subject rule in 1948, the year we decided McFadden.

2009After summarizing Proposition 115’s numerous provisions, the court in Raven, supra, 52 Cal.3d 336, initially addressed the petitioners’ single-subject challenge to the measure.

2023California Trial Lawyers addressed a single-subject challenge to a proposed initiative entitled the “ ‘Insurance Cost Control Initiative of 1988.’ ” (California Trial Lawyers, supra, 200 Cal.App.3d at p. 354 .) The appellate court issued a writ of mandate prohibiting placing the initiative on the ballot because the initiative’s section 8, regarding campaign contributions and conflicts of interest, rendered the initiative invalid under the single-subject rule. 21 The initiative was “lengthy, covering 120 typewritten pages and consisting of 67 sections.” (California Trial Lawyers, supra, 200 Cal

2023California Trial Lawyers addressed a single-subject challenge to a proposed initiative entitled the “ ‘Insurance Cost Control Initiative of 1988.’ ” (California Trial Lawyers, supra, 200 Cal.App.3d at p. 354 .) The appellate court issued a writ of mandate prohibiting placing the initiative on the ballot because the initiative’s section 8, regarding campaign contributions and conflicts of interest, rendered the initiative invalid under the single-subject rule. 21 The initiative was “lengthy, covering 120 typewritten pages and consisting of 67 sections.” (California Trial Lawyers, supra, 200 Cal

2003(Perry v. Jordan (1949) 34 Cal.2d 87, 92-93 [ 207 P.2d 47 ].) Therefore, cases applying the rule to initiatives are useful in applying the single-subject rule to legislation.

2003(Perry v. Jordan (1949) 34 Cal.2d 87, 92-93 [ 207 P.2d 47 ].) Therefore, cases applying the rule to initiatives are useful in applying the single-subject rule to legislation.

2011II, § 8, subd. (d).) An initiative measure does not violate the single-subject rule if its various provisions are “ ‘ “reasonably related to a common theme or purpose.” ’ ” (Manduley v. Superior Court (2002) 27 Cal.4th 537, 575 [ 117 Cal.Rptr.2d 168 , 41 P.3d 3 ].) In Manduley , the California Supreme Court considered a claim that Proposition 21, titled the Gang Violence and Juvenile Crime Prevention Act of 1998, violated the single subject rule.

2011The people’s initiative power “ ' “ ‘must be liberally construed ... to promote the democratic process.’ ” ’ ” (Brosnahan v. Brown (1982) 32 Cal.3d 236, 241 [ 186 Cal.Rptr. 30 , 651 P.2d 274 ], italics omitted.) Consistent with this principle, “ ‘ “ ‘ “[a]n initiative measure does not violate the single-subject requirement if, despite its varied collateral effects, all of its parts are ‘reasonably germane’ to each other,” and to the general purpose or object of the initiative.’ ” [Citation.] As [the California Supreme Court] explained, “the single-subject provision does not require that each o

2024(Senate of the State of Cal. v. Jones (1999) 21 Cal.4th 1142, 1156 .) However, because “ ‘the initiative process occupies an important and favored status in the California constitutional scheme,’ ” the rule “ ‘should not be interpreted in an unduly narrow or restrictive fashion that would preclude the use of the initiative process to accomplish comprehensive, broad-based reform in a particular area of public concern.’ ” (Briggs v. Brown (2017) 3 Cal.5th 808, 828 (Briggs).) There are two tests for measuring compliance with the single-subject rule.

2024(Briggs, supra, 3 Cal.5th at p. 829 , italics omitted; One Technologies, supra, at p. 760.) Yet the common purpose to which the initiative’s various provisions relate cannot be “ ‘so broad that 12 a virtually unlimited array of provisions could be considered germane,’ ” which would “ ‘essentially obliterat[e] the constitutional requirement.’ ” (Senate of the State of Cal. v. Jones, supra, 21 Cal.4th at p. 1162 ; Brosnahan v. Brown (1982) 32 Cal.3d 236, 253 [rule “forbids joining disparate provisions which [are] germane only to topics of excessive generality such as ‘government’ or ‘public welf

2006(See, e.g., Brosnahan, supra, 32 Cal.3d 236, 245 , 186 Cal.Rptr. 30 , 651 P.2d 274 ["`an initiative measure does not violate the single-subject requirement if . . . all of its parts are "reasonably germane" to each other,' and to the general purpose or object of the initiative" (italics omitted)]; Eu, supra, 54 Cal.3d 492, 512 , 286 Cal.Rptr. 283 , 816 P.2d 1309 , quoting Brosnahan; Jones, supra, 21 Cal.4th 1142, 1157 , 90 Cal.Rptr.2d 810 , 988 P.2d 1089 , quoting Eu. ) In applying the reasonably germane test, however, our decisions uniformly have considered only whether each of the parts of a

2006(See, e.g., Brosnahan, supra, 32 Cal.3d 236, 245 , 186 Cal.Rptr. 30 , 651 P.2d 274 ["`an initiative measure does not violate the single-subject requirement if . . . all of its parts are "reasonably germane" to each other,' and to the general purpose or object of the initiative" (italics omitted)]; Eu, supra, 54 Cal.3d 492, 512 , 286 Cal.Rptr. 283 , 816 P.2d 1309 , quoting Brosnahan; Jones, supra, 21 Cal.4th 1142, 1157 , 90 Cal.Rptr.2d 810 , 988 P.2d 1089 , quoting Eu. ) In applying the reasonably germane test, however, our decisions uniformly have considered only whether each of the parts of a

2002"The result of this inflexibility is that more often than not a proposed initiative represents the most extreme form of law which is considered politically expedient.... [¶] It is because of the voters' lesser ability to scrutinize a proposal and their total inability to propose modifications, that the multisubject initiative presents greater dangers than a similar multisubject legislative bill." ( Schmitz v. Younger (1978) 21 Cal.3d 90, 99-100 , 145 Cal.Rptr. 517 , 577 P.2d 652 "(dis. opn. of Manuel, J.).) Unfortunately, our subsequent cases have uncritically followed Perry v. Jordan , employ

2002"The result of this inflexibility is that more often than not a proposed initiative represents the most extreme form of law which is considered politically expedient.... [¶] It is because of the voters' lesser ability to scrutinize a proposal and their total inability to propose modifications, that the multisubject initiative presents greater dangers than a similar multisubject legislative bill." ( Schmitz v. Younger (1978) 21 Cal.3d 90, 99-100 , 145 Cal.Rptr. 517 , 577 P.2d 652 "(dis. opn. of Manuel, J.).) Unfortunately, our subsequent cases have uncritically followed Perry v. Jordan , employ

2023We do not believe the voters’ failure to require even greater precision invalidates the measure, since it is well established that an initiative may have ‘collateral effects’ without violating the single-subject rule.” (Kennedy Wholesale, supra, 53 Cal.3d at p. 254 .) 18 Kennedy Wholesale stands for the principle that an initiative survives a single-subject challenge even if it does not ensure that all revenue raised is directed at expenditures related to the initiative’s overall purpose.

2023Kennedy Wholesale expressly held that logrolling is not a separate basis to invalidate an initiative—rather, “[t]he single- subject rule is the method by which the state Constitution guards against that hazard.” (Kennedy Wholesale, supra, 53 Cal.3d at 24 p. 255.)8 We have already explained that Proposition 39 does not violate the single-subject rule.

2008The single-subject rule is intended to prevent “log-rolling by the Legislature, i.e., combining several proposals in a single bill so that legislators, by combining their votes, obtain a majority for a measure which would not have been approved if divided into separate bills.” (Harbor v. Deukmejian (1987) 43 Cal.3d 1078, 1096 [ 240 Cal.Rptr. 569 , 742 P.2d 1290 ].) In turn, “the requirement that the single subject of a bill shall be expressed in its title is to prevent misleading or inaccurate titles so that legislators and the public are afforded reasonable notice of the contents of a statute

2008The single-subject rule is intended to prevent “log-rolling by the Legislature, i.e., combining several proposals in a single bill so that legislators, by combining their votes, obtain a majority for a measure which would not have been approved if divided into separate bills.” (Harbor v. Deukmejian (1987) 43 Cal.3d 1078, 1096 [ 240 Cal.Rptr. 569 , 742 P.2d 1290 ].) In turn, “the requirement that the single subject of a bill shall be expressed in its title is to prevent misleading or inaccurate titles so that legislators and the public are afforded reasonable notice of the contents of a statute

2014It was to cure this evil that the constitution made it mandatory that a bill should embrace but one subject-matter, and to meet the case of such a “rider” actually slipping through, declared that any matter foreign to the title of the bill should be held void.’ ” (Planned Parenthood Affiliates v. Swoap (1985) 173 Cal.App.3d 1187, 1196 [ 219 Cal.Rptr. 664 ] (Planned Parenthood).) The single-subject rule is to be construed deferentially to minimize judicial interference in the activities of the legislative branch.

2014It was to cure this evil that the constitution made it mandatory that a bill should embrace but one subject-matter, and to meet the case of such a “rider” actually slipping through, declared that any matter foreign to the title of the bill should be held void.’ ” (Planned Parenthood Affiliates v. Swoap (1985) 173 Cal.App.3d 1187, 1196 [ 219 Cal.Rptr. 664 ] (Planned Parenthood).) The single-subject rule is to be construed deferentially to minimize judicial interference in the activities of the legislative branch.

2011A legislative provision is “germane” for purposes of the single-subject rule if it is “auxiliary to and promotive of the main purpose of the act or has a necessary and natural connection with that purpose . . . .” (Metropolitan Water Dist. v. Marquardt (1963) 59 Cal.2d 159, 172-173 [ 28 Cal.Rptr. 724 , 379 P.2d 28 ].) The loan provisions at issue here both promote the main purpose of the act (appropriations for the support of the government and public functions) and have a natural connection with that purpose. 2.

2008The single-subject rule is intended to prevent “log-rolling by the Legislature, i.e., combining several proposals in a single bill so that legislators, by combining their votes, obtain a majority for a measure which would not have been approved if divided into separate bills.” (Harbor v. Deukmejian (1987) 43 Cal.3d 1078, 1096 [ 240 Cal.Rptr. 569 , 742 P.2d 1290 ].) In turn, “the requirement that the single subject of a bill shall be expressed in its title is to prevent misleading or inaccurate titles so that legislators and the public are afforded reasonable notice of the contents of a statute

2023Under the first test, “ ‘ “ ‘[a]n initiative measure does not violate the single-subject requirement if, despite its varied collateral effects, all of its parts are “reasonably germane” to each other,’ and to the general purpose or object of the initiative. [Citations.]” ’ [Citation.] The ‘reasonably germane’ standard is applied ‘in an accommodating and lenient manner so as not to unduly restrict . . . the people’s right to package provisions in a 13 single bill or initiative.’ [Citations.]” ( Briggs, supra, 3 Cal.5th at pp. 828–829, italics omitted.) Our high court has clarified that the requ

2023Under the first test, “ ‘ “ ‘[a]n initiative measure does not violate the single-subject requirement if, despite its varied collateral effects, all of its parts are “reasonably germane” to each other,’ and to the general purpose or object of the initiative. [Citations.]” ’ [Citation.] The ‘reasonably germane’ standard is applied ‘in an accommodating and lenient manner so as not to unduly restrict . . . the people’s right to package provisions in a 13 single bill or initiative.’ [Citations.]” ( Briggs, supra, 3 Cal.5th at pp. 828–829, italics omitted.) Our high court has clarified that the requ

2011“Budget bills that substantively change existing law violate the single-subject rule.” (San Joaquin Helicopters v. Department of Forestry (2003) 110 Cal.App.4th 1549, 1558 [ 3 Cal.Rptr.3d 246 ].) The reason for this is apparent: a substantive bill making a change to existing law can be vetoed in its entirety by the Governor.

2011“Budget bills that substantively change existing law violate the single-subject rule.” (San Joaquin Helicopters v. Department of Forestry (2003) 110 Cal.App.4th 1549, 1558 [ 3 Cal.Rptr.3d 246 ].) The reason for this is apparent: a substantive bill making a change to existing law can be vetoed in its entirety by the Governor.

2007Co. v. Deukmejian (1989) 48 Cal.3d 805, 841-842 [ 258 Cal.Rptr. 161 , 771 P.2d 1247 ].) *1341 The Council relies heavily on two Court of Appeal decisions that held initiative measures violated the single-subject rule: California Trial Lawyers Assn. v. Eu (1988) 200 Cal.App.3d 351 [ 245 Cal.Rptr. 916 ] (CTLA) and Chemical Specialties Manufacturers Assn., Inc. v. Deukmejian (1991) 227 Cal.App.3d 663 [ 278 Cal.Rptr. 128 ] (Chemical).

2007Co. v. Deukmejian (1989) 48 Cal.3d 805, 841-842 [ 258 Cal.Rptr. 161 , 771 P.2d 1247 ].) *1341 The Council relies heavily on two Court of Appeal decisions that held initiative measures violated the single-subject rule: California Trial Lawyers Assn. v. Eu (1988) 200 Cal.App.3d 351 [ 245 Cal.Rptr. 916 ] (CTLA) and Chemical Specialties Manufacturers Assn., Inc. v. Deukmejian (1991) 227 Cal.App.3d 663 [ 278 Cal.Rptr. 128 ] (Chemical).

2008Jones stated only that “preelection review might be appropriate upon a ‘clear showing of invalidity.’ ” (Jones, supra, 21 Cal.4th at p. 1154 , quoting Brosnahan v. Eu (1982) 31 Cal.3d 1, 4 [ 181 Cal.Rptr. 100 , 641 P.2d 200 ] (Brosnahan I).) As the high court has explained, “a majority of the court in Brosnahan I was not persuaded that, in that instance, the challenged *19 initiative violated the single-subject rule” and thus had deferred ruling on the merits of a single subject challenge to the initiative at issue until after the election.

2008Jones stated only that “preelection review might be appropriate upon a ‘clear showing of invalidity.’ ” (Jones, supra, 21 Cal.4th at p. 1154 , quoting Brosnahan v. Eu (1982) 31 Cal.3d 1, 4 [ 181 Cal.Rptr. 100 , 641 P.2d 200 ] (Brosnahan I).) As the high court has explained, “a majority of the court in Brosnahan I was not persuaded that, in that instance, the challenged *19 initiative violated the single-subject rule” and thus had deferred ruling on the merits of a single subject challenge to the initiative at issue until after the election.

2007Co. v. Deukmejian (1989) 48 Cal.3d 805, 841-842 [ 258 Cal.Rptr. 161 , 771 P.2d 1247 ].) *1341 The Council relies heavily on two Court of Appeal decisions that held initiative measures violated the single-subject rule: California Trial Lawyers Assn. v. Eu (1988) 200 Cal.App.3d 351 [ 245 Cal.Rptr. 916 ] (CTLA) and Chemical Specialties Manufacturers Assn., Inc. v. Deukmejian (1991) 227 Cal.App.3d 663 [ 278 Cal.Rptr. 128 ] (Chemical).

2007Co. v. Deukmejian (1989) 48 Cal.3d 805, 841-842 [ 258 Cal.Rptr. 161 , 771 P.2d 1247 ].) *1341 The Council relies heavily on two Court of Appeal decisions that held initiative measures violated the single-subject rule: California Trial Lawyers Assn. v. Eu (1988) 200 Cal.App.3d 351 [ 245 Cal.Rptr. 916 ] (CTLA) and Chemical Specialties Manufacturers Assn., Inc. v. Deukmejian (1991) 227 Cal.App.3d 663 [ 278 Cal.Rptr. 128 ] (Chemical).

2023(Kennedy Wholesale, Inc. v. State Bd. of Equalization (1991) 53 Cal.3d 245, 255 ; accord, California Gillnetters Assn. v. Department of Fish & Game (1995) 39 Cal.App.4th 1145 , 1162 & fn. 11.) While concerns about voters’ understanding of section 7465(c)(4) may bear on our interpretation of the statute for the purposes of plaintiffs’ separation of powers challenge, as we discuss post, these concerns are not sufficient to rescue plaintiffs’ otherwise unpersuasive single-subject rule argument. 38 IV.

2023(Kennedy Wholesale, Inc. v. State Bd. of Equalization (1991) 53 Cal.3d 245, 255 ; accord, California Gillnetters Assn. v. Department of Fish & Game (1995) 39 Cal.App.4th 1145 , 1162 & fn. 11.) While concerns about voters’ understanding of section 7465(c)(4) may bear on our interpretation of the statute for the purposes of plaintiffs’ separation of powers challenge, as we discuss post, these concerns are not sufficient to rescue plaintiffs’ otherwise unpersuasive single-subject rule argument. 38 IV.

2024The single-subject rule refers to article II, section 8, subdivision (d), which provides: “An initiative measure embracing more than one subject may not be submitted to the electors or have any effect.” The rule applies to both local and statewide initiatives (Shea Homes Limited Partnership v. County of Alameda (2003) 110 Cal.App.4th 1246, 1255 ) and is intended to minimize the risk of voter confusion and deception.

2024The single-subject rule refers to article II, section 8, subdivision (d), which provides: “An initiative measure embracing more than one subject may not be submitted to the electors or have any effect.” The rule applies to both local and statewide initiatives (Shea Homes Limited Partnership v. County of Alameda (2003) 110 Cal.App.4th 1246, 1255 ) and is intended to minimize the risk of voter confusion and deception.

2010The court rejected the claim that the provisions of the trailer bill were "reasonably germane" to the objects of the measure, which were asserted to be to "`fiscal affairs'" and "`statutory adjustments.'" ( Id. at pp. 1100-1101.) According to the court, in such case, the bill "encompass[ed] matters of `excessive generality'" ( id. at p. 1100), as "[t]he number and scope of topics germane to `fiscal affairs' in this sense is virtually unlimited." ( Id. at pp. 1100-1101.) *617 (11) Relying on League of Women Voters v. Eu (1992) 7 Cal.App.4th 649 [ 9 Cal.Rptr.2d 416 ], petitioners are confident t

2010The court rejected the claim that the provisions of the trailer bill were "reasonably germane" to the objects of the measure, which were asserted to be to "`fiscal affairs'" and "`statutory adjustments.'" ( Id. at pp. 1100-1101.) According to the court, in such case, the bill "encompass[ed] matters of `excessive generality'" ( id. at p. 1100), as "[t]he number and scope of topics germane to `fiscal affairs' in this sense is virtually unlimited." ( Id. at pp. 1100-1101.) *617 (11) Relying on League of Women Voters v. Eu (1992) 7 Cal.App.4th 649 [ 9 Cal.Rptr.2d 416 ], petitioners are confident t

2002If doubts can reasonably be resolved in favor of the use of this reserve power, courts will preserve it.' [Citations.]" ( Ibid. ) Accordingly, "the single-subject requirement should not be interpreted in an unduly narrow or restrictive fashion that would preclude the use of the initiative process to accomplish comprehensive, broad-based reform in a particular area of public concern." ( Senate of the State of Cal. v. Jones (1999) 21 Cal.4th 1142, 1157 , 90 Cal.Rptr.2d 810 , 988 P.2d 1089 .) The standard consistently applied in this context is that an initiative measure comports with the single-

2002If doubts can reasonably be resolved in favor of the use of this reserve power, courts will preserve it.' [Citations.]" ( Ibid. ) Accordingly, "the single-subject requirement should not be interpreted in an unduly narrow or restrictive fashion that would preclude the use of the initiative process to accomplish comprehensive, broad-based reform in a particular area of public concern." ( Senate of the State of Cal. v. Jones (1999) 21 Cal.4th 1142, 1157 , 90 Cal.Rptr.2d 810 , 988 P.2d 1089 .) The standard consistently applied in this context is that an initiative measure comports with the single-