Placeholders, So-Called “Spot Bills,” Cannot Be Used For Emergency Legislation.

The appellate court’s first paragraph speaks for itself:  “The narrow, but potentially recurring and important, question we address in these writ proceedings is whether the California Constitution, as amended by the voters in 2010, allows the Legislature to identify blank bills with an assigned number but no substance (so-called “spot bills”) in the budget bill, pass the budget, and thereafter add content to the placeholder and approve it by a majority vote as urgency legislation. (Cal. Const., Art. IV, §12, subds. (d) and (e).) We conclude that spot bills which remain empty of content at the time the budget is passed are not bills that can be identified within the meaning of article IV, section 12, subdivision (e)(2) of the California Constitution and enacted as urgency legislation by a mere majority vote.” Howard Jarvis Taxpayers Association v. Debra Bowen, as Secretary of State; Legislature of the State of California  (Cal. App. Third Dist.; January 18, 2013) 212 Cal.App.4th 1298.