March 9, 2026
Court of Appeal of the State of California, First Appellate District, Division Four
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.