Raven v. Deukmejian
California Supreme Court
801 P.2d 1077 (1990)

- Written by Joe Cox, JD
Facts
In a 1990 primary election, California voted in favor of a ballot initiative, Proposition 115, also known as the Crime Victims Justice Reform Act. A group of taxpayers and voters including Robert Raven (plaintiff) filed suit against Governor George Deukmejian and other officials, seeking a ruling that Proposition 115 both violated the single-subject rule of the California constitution and attempted to revise rather than amend the state constitution. California law allowed initiatives that amended the state constitution, but a revision of the state constitution could be accomplished only by a specially called convention, which would ratify a new constitution. Specifically at issue was a section of Proposition 115 that directed the California judiciary to not construe prior law to afford greater rights to criminal defendants than those established by the federal Constitution—the preamble to Proposition 115 recited how California Supreme Court decisions had expanded those rights in an unnecessary manner. The case was transferred to the California Supreme Court. The state argued that the initiative brought about minimal to no quantitative change in the state constitution and should be validated. Raven argued that the effect of the proposition would grossly restructure, or strip, the power of the judicial branch, and that it should be invalidated.
Rule of Law
Issue
Holding and Reasoning (Lucas, C.J.)
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