California Legal Brief

The Rule of Citizens Against Marketplace Apartment/Condo Development v. City of San Ramon is that a city does not abuse its discretion in approving an infill housing development despite general plan language encouraging preparation of a "master plan," under circumstances where the general plan uses discretionary language ("encourage") rather than mandatory requirements and the project achieves the substantive objectives of circulation, access, and visibility improvements while introducing mixed-use residential development.

The Rule of Alameda County Taxpayers' Association v. City of Oakland is that specific references in an initiative measure identifying a private corporation as currently filling a role that involves functions and duties violate article II, section 12, but such references can be severed without invalidating the remainder of the measure, under circumstances where the references are grammatically, functionally, and volitionally separable and the measure contains a severability clause.