Court Interprets "Full Text" Rule

Government Code Section 9238 requires that a referendum petition contain the "full text" of the measure being challenged. This seemingly straightforward command has given rise to a surprising amount of litigation. The latest case is Lin v. City of Pleasanton (here). This decision holds that, at most, a referendum petition must include the ordinance being challenged and any documents attached to the ordinance or incorporated by reference. Indeed, the court left open the possibility in footnote 4, citing Defend Bayview Hunters Point Committee v. City and County of San Francisco, 167 Cal. App. 4th 846 (2008), that the full text requirement could be satisfied in some situations even if not every document incorporated or attached to the challenged measure was included. This case continues the reasonable construction of these textual requirements begun in We Care -- Santa Paula v. Herrera, 139 Cal. App. 4th 387 (2006), which followed a string of more exacting decisions. It is sound and there is no reason why the Supreme Court should grant review.