California Proposition 32, the "Paycheck Protection" Initiative (2012)

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Proposition 32
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Type:State statute
Referred by:Petition signatures
Topic:Paycheck protection
Status:On the ballot
Proposition 32, the "Paycheck Protection" Initiative, is on the November 6, 2012 ballot in California as an initiated state statute.[1]

If approved, Proposition 32 will:

  • Ban both corporate and union contributions to state and local candidates
  • Ban contributions by government contractors to the politicians who control contracts awarded to them
  • Ban automatic deductions by corporations, unions, and government of employees’ wages to be used for politics

No exemptions, no loopholes

A similar proposition, Proposition 75, was on the 2005 ballot. Proposition 226, on the 1998 ballot, also sought to enact paycheck protection.[2]


Jerry Brown signed SB 202 on October 7, 2011. SB 202 mandates that elections on ballot propositions can take place only in the state's November general elections. This changes a 50-year tradition in the state, begun in 1960, of voting on ballot propositions on the June primary ballot as well as the November general election ballot.[3]

Several pundits speculated that Brown and the Democratic members of the California State Legislature who sponsored SB 202 were moved to action by the Paycheck Protection Initiative, and the possibility that it would gain a spot on the June 5, 2012 primary ballot in the state.

  • According to Bill Whalen, "...before Brown’s intervention, one such conservative idea – a big one – was headed for a showdown in June 2012: weakening Big Labor’s clout by preventing unions from collecting dues for political purposes without a worker’s annual consent. [Under SB 202], that gets moved to November."[4]
  • Dan Walters, a leading political journalist in the state, said, "Everyone knows that passing SB 202 was to diminish chances that voters would pass a so-called "paycheck protection" measure that would eat into unions' ability to gather campaign funds from public employees – money that almost always goes to Democrats."[5]

Thad Kousser, a political-science professor at UC San Diego, says that the Paycheck Protection Initiative could have a strong impact on the public sector (government employee) unions in the state: "Defeating this has got to be the top goal of labor. If they don't, they could become almost extinct in California politics."[6]

Text of measure

See also: Complete text of Proposition 32 and Ballot titles, summaries and fiscal statements for California's 2012 ballot propositions


Political Contributions by Payroll Deduction. Contributions to Candidates. Initiative Statute.

Note: The original title given to Proposition 32 by election officials during the petition circulation stage was, "Prohibits Political Contributions by Payroll Deduction. Prohibitions on Contributions to Candidates. Initiative Statute."


See also: Proposition 32 lawsuits

Proposition 32's ballot label has gone through three versions. The third and final version was given to it by a Sacramento County Superior Court Judge on August 13, 2012.[7]

The final label is:

"Prohibits unions from using payroll-deducted funds for political purposes. Applies same use prohibition to payroll deductions, if any, by corporations or government contractors. Prohibits union and corporate contributions to candidates and their committees. Prohibits government contractor contributions to elected officers or their committees."

The second version, given to Proposition 32 after it qualified for the ballot, said:

"Restricts union political fundraising by prohibiting use of payroll-deducted funds for political purposes. Applies same use restrictions to payroll deductions, if any, by corporations or government contractors. Prohibits union and corporate contributions to candidates and their committees. Prohibits government contractor contributions to elected officers or their committees."

The original version given to Proposition 32 by election officials during the petition circulation stage was:

"Restricts union political fundraising by prohibiting use of payroll-deducted funds for political purposes. Same use restriction would apply to payroll deductions, if any, by corporations or government contractors. Permits voluntary employee contributions to employer or union committees if authorized yearly, in writing. Prohibits unions and corporations from contributing directly or indirectly to candidates and candidate-controlled committees. Other political expenditures remain unrestricted, including corporate expenditures from available resources not limited by payroll deduction prohibition. Limits government contractor contributions to elected officers or officer-controlled committees."

Estimated fiscal impact

See also: Fiscal impact statements for California's 2012 ballot propositions

(This is a summary of the initiative's estimated "fiscal impact on state and local government" prepared by the California Legislative Analyst's Office and the Director of Finance.)

Increased costs to state and local government—potentially exceeding $1 million annually—to implement and enforce the measure’s requirements.

The estimated fiscal impact in the voter guide differs from the fiscal statement that was originally provided by election officials to Proposition 32 when it was in the petition circulation stage. That fiscal statement said, "Increased state implementation and enforcement costs of up to hundreds of thousands of dollars annually, potentially offset in part by revenues from fines."


The "Yes on Proposition 32" campaign website logo


  • The main campaign supporting the measure is YES on 32, Stop Special Interest Money Now!

The arguments in favor of Proposition 32 in the state's official voter guide were submitted by:

  • Gloria Romero. Romero is the state director of Democrats for Education Reform. She is also a former California state senator.
  • Gabriella Holt. Holt is the president of Citizens for California Reform.
  • John Kabateck. Kabateck is the executive director of the California chapter of the National Federation of Independent Business.
  • Marian Bergeson. Bergeson is a former California Secretary of Education.
  • Jon Coupal. Coupal is the president of the Howard Jarvis Taxpayers Association.
  • The Hon. John Arguelles. Arguelles is a retired justice of the California Supreme Court.

Other supporters include:

  • Former U.S. Secretary of State George Shultz. He says, "This initiative gets to the heart of one of the most corrosive elements in politics: campaign contributions...For too long, special interest money has dominated our politics, muting the voice of average Californians."[8]
  • Richard Riordan, a former mayor of Los Angeles.[9]

Arguments in favor

The arguments presented in favor of Proposition 32 in the state's official voter guide include:

  • "Politicians take millions in campaign contributions from corporations and government unions and then vote the way those special interests tell them. Politicians end up working for special interests, not voters. The result: massive budget deficits and abuses like lavish pensions and bad teachers we can’t fire."
  • "Special interests have spent tens of millions of dollars to prevent Prop. 32 from cutting the money tie between them and politicians. They’ll say anything to protect the status quo. They’ve invented a false, bogus, red-herring argument: They claim Prop. 32 has a loophole to benefit the wealthy and corporations to fund independent PACs. The fact is both unions and corporations fund independent political committees protected by the Constitution that cannot be banned."
  • "Politicians hold big-ticket, lavish fundraisers at country clubs, wine tastings and cigar smokers. Fat-cat lobbyists attend these fundraisers and hand over tens of millions of dollars in campaign contributions. Most happen when hundreds of bills are up for votes, allowing politicians and special interests to trade favors: Giving multi-million dollar tax loopholes to big developers, wealthy movie producers and out-of-state corporations; exempting contributors from the state’s environmental rules; handing out sweetheart pension deals for government workers; protecting funding for wasteful programs like the high-speed train to nowhere, even as they are cutting funds for schools and law enforcement while proposing higher taxes."
  • "Stops special interests from taking political deductions from employee paychecks to guarantee every dollar given for politics is strictly voluntary. Prop. 32 will ensure that California workers have the right to decide how to spend the money they earn. They shouldn’t be coerced to contribute to politicians or causes they disagree with."
  • "Today, it is legal for politicians to give contracts to political donors, shutting out small businesses in the process. Prop. 32 will end this special treatment and the waste it causes, like a $95 million state computer system that didn’t work."

Other arguments in favor of Proposition 32 include:

  • According to Jake Suski, a spokesperson for the "yes" campaign, "This initiative is exclusively about the stranglehold that special interests have had over California's political system and whether voters are ready to demand reform. Voters are demanding reform and change. They're willing to do something, to say no to special interests."[9]
  • The editorial board of the Wall Street Journal writes, "If California voters hope to stand a chance of reining in such benefits and fixing their dysfunctional state, they'll have to break the government union political monopoly this November."[11]
  • Margaret A. Bengs, a former spokeswoman for state agencies, says, "It is well known that big public employee unions and other special interests have an inordinate control over California government, control that stymies badly needed reforms."[12]


Total campaign cash Invest.png
Category:Ballot measure endorsements Support: $9,000,000
Circle thumbs down.png Opposition: $45,600,000

As of October 1, 2012, the "yes" campaign has raised about $9 million.[13][14]

These are the $50,000 and over donors to the "yes" campaign as of October 1, 2012:

Donor Amount
American Future Fund $4,080,000
Charles Munger, Jr. $992,204
Thomas M. Siebel $500,000
William Bloomfield, Jr. $300,000
Larry Smith $260,701
Jerry Perenchio $250,000
Citizen Power Campaign $230,317
B. Wayne Hughes $200,000
Lincoln Club of Orange County $168,633
William Oberndorf $150,000
Protect Prop 13 (HJTA) $125,000
Robert J. Oster $101,000
Frank E. Baxter $100,000
Timothy C. Draper $100,000
William L. Edwards $100,000
Howard F. Ahmanson $50,000
Charles B. Johnson $50,000
Franklin P. Johnson, Jr. $50,000
Nicoletta Holdings Company $50,000
Richard J. Riordan $50,000
Steven A. Laub $50,000


The "No on Proposition 32" campaign website logo


  • The main campaign against the measure is No on 32, Stop the Special Exemptions Act.

The arguments against Proposition 32 in the state's official voter guide were submitted by:

Other opponents include:

Arguments against

The arguments in opposition to Proposition 32 presented in the state's official voter guide include:

  • "Proposition 32 is not what it seems. Prop. 32 promises 'political reform' but is really designed by special interests to help themselves and harm their opponents."
  • "Business Super PACs and independent expenditure committees are exempt from Prop. 32’s controls. These organizations work to elect or defeat candidates and ballot measures but aren’t subject to the same contribution restrictions and transparency requirements for campaigns themselves. A recent Supreme Court decision allows these groups to spend unlimited amounts of money. Prop. 32 does nothing to deal with that. If Prop. 32 passes, Super PACs, including committees backed by corporate special interests, will become the major way campaigns are funded. These groups have already spent more than $95,000,000 in California elections since 2004. Our televisions will be flooded with even more negative advertisements."
  • "Real campaign reform treats everyone equally, with no special exemptions for anyone. Proposition 32 was intentionally written to exempt thousands of big businesses like Wall Street investment firms, hedge funds, developers, and insurance companies. Over 1000 of the companies exempted by this measure are listed as Major Donors by the California Secretary of State. They have contributed more than $10,000,000 to political campaigns, just since 2009."
  • "This measure says it prohibits unions from using payroll-deducted funds for political purposes. It says it also applies to corporations, so it sounds balanced. But 99% of California corporations don’t use payroll deductions for political giving; they would still be allowed to use their profits to influence elections."
  • "Some say 'this is unbalanced but it’s a step forward.' Here’s the problem with that. Restricting unions and their workers while not stopping corporate special interests will result in a political system that favors corporate special interests over everyone else."

Other arguments against Proposition 32 include:

  • Art Pulaski, executive secretary-treasurer of the California Labor Federation, says, "It's not enough for them to have taken our houses and it's not enough for them to make millions off the TARP funding and federal government support for the banks, now they want even more. They want us to not even have a voice in politics whatsoever."[1]
  • Columnist Thomas Elias says, the "initiative's ban on contributions to candidate-controlled committees is meaningless, merely a cover for another blatant attempt to reduce funds for liberal candidates while letting contributions to conservatives continue unfettered."[19]
  • Ron Lind, the president of United Food and Commercial Workers Local 5, says, "The measure is a wolf in sheep's clothing designed to fool voters into approving a corporate power grab that will lead to even more corporate influence over our political system. What the backers won't say publicly is that they've written a giant loophole to allow for unlimited corporate spending on campaigns while furthering their real agenda of silencing the voices of middle-class workers and their unions."[20]
  • State representative Linda Sanchez says, "This paycheck deception is the No. 1 target to silence the voices of hard-working families, and it's a crime."[21]
  • State representative Judy Chu says, "This is the most dangerous proposition of all time. It will silence the union members and their voices."[21]
  • Trudy Schafer of the California League of Women Voters says, "It promises political reform but it's really designed by its special interest backers to help themselves and harm their opponents."[17]


Total campaign cash Invest.png
Category:Ballot measure endorsements Support: $9,000,000
Circle thumbs down.png Opposition: $45,600,000

It was predicted early on that the state's public sector (government employee) unions would provide up to $28 million to the campaign to defeat Proposition 32. By late September, however, the level of giving to the "no" campaign soared past that early estimate.[6][13],[14] The Sacramento Bee reports, "Now, on the heels of an election that saw unions handed a major defeat last week in Wisconsin, the opposing camps in California soon will launch a campaign battle likely to consume $50 million or more in political spending."[9]

According to Dan Morain, the state's public employee unions may find themselves torn between funding the campaign to defeat the Paycheck Protection Initiative and funding the campaign to pass the Proposition 30 (the Jerry Brown/"Millionaire's Tax" initiative). Morain says, "To help fund the campaign, Brown needs the help of organized labor. But unions will be busy trying to kill a separate initiative promoted by conservatives that would strip them of their ability to raise and spend money on campaigns."[22]

This is a list of the $100,000 and over donors to the "no" campaign as of October 1, 2012:[23]

Donor Amount
California Teachers Association $18,165,362
SEIU/California State Council of Service Employees $8,848,131
AFSCME $3,142,892
California Professional Firefighters $2,602,580
California School Employees Association $1,601,347
California Faculty Association $1,530,146
Peace Officers Research Association of California PAC $1,376,846
California Labor Federation (AFL-CIO/Change to Win) $1,372,431
California/American Federation of Teachers $800,000
International Association of Firefighters $500,000
Professional Engineers in California Government $500,000
Thomas Steyer $500,000
California Statewide Law Enforcement Association $426,552
California State Pipe Trades Council $250,000
Los Angeles Police Protective League's Public Safety First PAC $250,000
Peace Officers Research Association $250,000
Million More Voters (AFL-CIO) $245,516
Northern California District Council of Laborers' Issues $150,000
State Building and Construction Trades Council of California $129,718
United Transportation Union $105,000
San Bernardino County Safety Employees' Benefit Association $100,000
John Perez Ballot Measure Committee $100,000
United Domestic Workers of America $100,000
Union of American Physicians & Dentists $100,000
California Association of Psychiatric Technicians $100,000


Political consultant Gale Kaufman is managing the opposition campaign. She ran the campaign against a similar measure, Proposition 226 in 1998.[6],[24]

Editorial opinion

2012 propositions
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June 5
Proposition 28
Proposition 29
November 6
Proposition 30
Proposition 31
Proposition 32
Proposition 33
Proposition 34
Proposition 35
Proposition 36
Proposition 37
Proposition 38
Proposition 39
Proposition 40
EndorsementsFull text
Ballot titlesFiscal impact
Local measures
See also: Endorsements of California ballot measures, 2012

"Yes on 32"

  • The Bakersfield Californian: "As desperate as the state is for money, we oppose Prop. 30 because it promotes the same bad budgeting policies that pushed the state into the mess it's in today."[25]
  • The Orange County Register: "Anyone familiar with California politics knows that the most powerful forces, by far, in the state Capitol are the public-employee unions. Their clout was demonstrated this year when the California Teachers Association, the most powerful of them all, killed Senate Bill 1530, which would have made it easier to fire bad teachers for actions 'that involve certain sex offenses, controlled-substance offenses or child abuse offenses.' SB1530 was not concocted by a conservative Republican, but by state Sen. Alex Padilla of Los Angeles, a liberal Democrat. The bill advanced after several cases of teacher abuse against children came to light, especially a disgusting scenario allegedly involving Los Angeles Unified School District teacher Mark Berndt. The bill passed overwhelmingly in the state Senate, 33-4. Then the CTA killed it in the Assembly Education Committee."[26]
  • The Redding Record Searchlight: "Nothing in Proposition 32 would stop unions from holding fundraisers, from asking members to write a check to support a good cause or candidate — from raising money just like any other political advocate. It would, however, slow the river of money that has drowned independent thinkers in Sacramento."[27]
  • The San Diego Union-Tribune: "Of all the measures on the California ballot this fall, the most important is Proposition 32. It has the potential to change the balance of power in state and local governments in a hugely constructive way. How? By limiting the power of California’s unions, the 21st-century version of the railroad companies that were so perniciously powerful a century ago that Gov. Hiram Johnson established direct democracy so voters could overrule a state Capitol in thrall to one interest group."[28]

"No on 32"

  • The Bay Area Reporter: "This is an anti-labor measure concocted by southern California conservatives under the guise of campaign finance reform."[29]
  • The Contra Costa Times: "If Proposition 32 did what supporters claim -- limit all special-interest money from corrupting the political system -- we would race to endorse it. It doesn't. It actually tilts the political playing field in favor of the wealthy and corporations."[30]
  • The Los Angeles Times: "Proposition 32 is a deceptive measure that would disproportionately weaken some special interests while leaving others essentially unaffected. Those who have seen its list of backers will not be surprised to learn that it would have a devastating effect on labor unions' political fundraising efforts and only a trivial impact on corporate spending."[31]
  • The Merced Sun-Star: "Proposition 32 would ban unions and corporations from using automatic paycheck deductions to raise money for political purposes. That might sound reasonable, except that it's loaded. Unions rely on payroll deductions, corporations do not."[32]
  • The Sacramento Bee: "Our recommendation to reject Proposition 32 is not a vote of confidence for public employee unions. They have overreached too often and have too much clout with too many Democrats. Lawmakers should take action to make it easier for employees who disagree with union politics to opt out of making campaign donations. But Proposition 32 would tilt the system in favor of corporations and business trade groups."[33]
  • The San Francisco Bay Guardian: "This is by far the most dangerous and deceptive measure on the ballot, one that threatens to cripple the ability of labor unions to engage meaningfully in the political process."[34]
  • The San Francisco Chronicle: "Proposition 32 purports to be an even-handed attempt to reduce the influence of special interests in California. It is anything but balanced ... Organized labor has made defeat of Prop. 32 its highest priority in California because of what is unquestionably its most consequential element: A prohibition on the use of payroll deductions for political purposes."[35]
  • The Santa Cruz Sentinel: "And while we've editorialized against the influence of unions on lawmakers in this state, and for how their bankrolling liberal Democrats has kept meaningful pension, education, government efficiency and budget reforms stalled, in this case, we reluctantly agree this measure has too many flaws, and urge voters to reject Prop. 32."[37]
  • The Ventura County Star: "This measure claims to be aimed at cleaning up politics by clamping new restrictions on contributions. In reality, it amounts to a cynical ploy because it ignores some of the biggest problems of money in politics while putting handcuffs only on the political opponents of some of the measure's biggest backers."[38]

Polling information

See also: Polls, 2012 ballot measures

A Field Poll on Proposition 32 was conducted between September 6 and September 18.[39]

The Public Policy Institute of California polled Proposition 32 for the first time in mid-September.[40]

Date of Poll Pollster In favor Opposed Undecided Number polled
September 9-16, 2012 PPIC 42% 49% 9% 2,003
September 6-18, 2012 Field Poll 38% 44% 18% 1,183
September 17-23, 2012 USC Dornsife/Los Angeles Times 36% 44% 20% 1,504
October 7-10, 2012 California Business Roundtable 51.4% 38.3% 10.3% 830
October 11-15, 2012 Reason-Rupe 45% 48% 7% 696
October 14-21, 2012 PPIC 39% 53% 7% 2,006
October 21-28, 2012 California Business Roundtable 44.7% 44.8% 10.5% 2,115
October 17-30, 2012 Field Poll 34% 50% 16% 1,912

Path to the ballot

See also: California signature requirements
See also: California ballot initiative petition signature costs


See also: List of ballot measure lawsuits in 2012

Supporters and opponents of Proposition 32 filed lawsuits seeking to alter the official ballot text that will appear in the state's official voter guide. The official voter guide comes in an online version and is also mailed to every registered voter in the state.[41]

The court ruled partly in favor and partly against the lawsuit filed by Proposition 32 supporters. The court altogether denied the request of Proposition 32's opponents.[41]

Ashlee Titus v. Debra Bowen[7]

Ashlee Titus v. Debra Bowen is the lawsuit filed by Proposition 32 supporters. They asked the court to do two things; the court agreed with them on one request.[7]

  • First, Titus asked that the court change the state's official summary/label. The court agreed with this request.

The old ballot summary said:

"Restricts union political fundraising by prohibiting use of payroll-deducted funds for political purposes. Applies same use restrictions to payroll deductions, if any, by corporations or government contractors. Prohibits union and corporate contributions to candidates and their committees. Prohibits government contractor contributions to elected officers or their committees."

The new, court-ordered summary/label, with deleted text shown in strike-out text and added language shown in italics, says:

"Restricts Prohibits unions from using payroll-deducted funds for political purposes. Applies same use restrictions prohibition to payroll deductions, if any, by corporations or government contractors. Restricts Prohibits union and corporate contributions to candidates and their committees. Limits Prohibits government contractor contributions to elected officers or their committees.

The key change was to the consistent use of "prohibits", rather than "restricts". In their lawsuit, according to "Yes on 32" campaign spokesperson Jake Suski, the use of the word "restrict", which was the word chosen by the Attorney General of California, was misleading. Suski said, "Voters deserve to be informed that Prop. 32 doesn't just reduce direct contributions from corporations and unions to politicians, it eliminates them entirely."[41] After the lower court's ruling came out, Kamala Harris, the Attorney General of California, went to a higher level court and filed a petition asking for immediate review of the lower court's decision. This request was denied.[42]

"Yes on 32" supporters made an additional request of the court. This second request was denied. This was a request to have the phrase "Other political expenditures remain unrestricted, including corporate expenditures from available resources not limited by payroll deduction prohibition" removed from the state's official materials.

Lou Paulson v. Debra Bowen[43]

Lou Paulson v. Debra Bowen is the lawsuit filed by the "No on 32" campaign. Their request to the court was denied.[43]

The "No on 32" campaign's lawsuit challenged ballot language they believed might mislead voters about whether payroll deductions could still occur if a worker provided the state with written permission when in fact, under the provisions of Proposition 32, the state cannot engage in the practice of payroll deductions regardless of whether or not a worker gives permission.[41]

External links

Suggest a link

Basic information:




  1. 1.0 1.1 1.2 1.3 Business Week, "Measure to curb union, corporate clout qualifies", December 8, 2011
  2. Human Events, "Paycheck Protection Makes a California Comeback", October 19, 2011
  3. KCRA, "At 100, California Direct Democracy Gets Facelift", October 10, 2011
  4. Ricochet, "California's Initiative Process Turns 100", October 10, 2011
  5. Sacramento Bee, "California politicans use power to fix the ballot game", January 30, 2012
  6. 6.0 6.1 6.2 Mercury News, "High-stakes labor battle coming to California", January 30, 2012
  7. 7.0 7.1 7.2 Superior Court of the State of California County of Sacramento, "Ashlee Titus v. Debra Bowen"
  8. 8.0 8.1 Sacramento Bee, "Backers of 'paycheck protection' measure submit signatures", October 7, 2011
  9. 9.0 9.1 9.2 Sacramento Bee, "Unions will start spending millions to tout message about Calif. campaign donation ballot measure", June 9, 2012
  10. Walnut Creek Patch, "California Republicans Oppose Proposed Tax Measures", August 12, 2012
  11. Wall Street Journal, "California's Public Union Referendum", August 10, 2012
  12. Sacramento Bee, "Viewpoints: Prop. 32 is a small check on special interests", August 11, 2012
  13. 13.0 13.1 Sacramento Bee, "Unions give $500,000 to oppose 'paycheck' ballot measure", May 22, 2012
  14. 14.0 14.1 Sacramento Bee, "Firefighters group gives $1 million to fight campaign finance measure", July 6, 2012
  15. Los Angeles Times, "Good-government groups call Proposition 32 deceptive", July 23, 2012
  16. Sacramento Bee, "'Reform' initiative wears a soiled white hat", December 22, 2011
  17. 17.0 17.1 17.2 Contra Costa Times, "Union political donation ballot measure questioned", July 23, 2012
  18. Walnut Patch, "Democratic Party Picks State Ballot Measures to Support", July 30, 2012
  19. Redding Record-Searchlight, "One-sided 'paycheck protection'", February 26, 2012
  20. Mercury News, "Ron Lind: Special interest ballot measure really is just anti-union", March 2, 2012
  21. 21.0 21.1 San Gabriel Valley Tribune, "Teamsters rally against ballot initiative in El Monte", April 14, 2012
  22. Sacramento Bee, "Dan Morain: The heat is on Jerry Brown and the Democrats", June 10, 2012
  23. Sacramento Bee, "Unions Kick in another $1.1 million to defeat Proposition 32", August 10, 2012
  24. Sacramento Bee, "Californians to Watch: Campaign consultant Gale Kaufman makes labor's case to voters", December 27, 2011
  25. Bakersfield Californian, "Yes on 32: Check undue union influence", October 6, 2012
  26. Orange County Register, "Editorial: Yes on Prop. 32 (unions)", October 3, 2012
  27. Redding Record Searchlight, "Editorial: Prop. 32 would restore balance to Sacramento", September 29, 2012
  28. San Diego Union-Tribune, "Yes on 32: Break the union stranglehold", October 5, 2012
  29. Bay Area Reporter, "Editorial: State ballot measures", September 20, 2012
  30. Contra Costa Times, "Summary of our endorsements on state propositions", September 22, 2012
  31. Los Angeles Times, "No on Proposition 32", October 3, 2012
  32. Merced Sun-Star, "Our View: Prop 32 goes after unions, not big money", October 4, 2012
  33. "Sacramento Bee", "Endorsements: Proposition 32 power play deserves a 'no' vote", September 23, 2012
  34. San Francisco Bay Guardian, "Endorsements 2012: State ballot measures", October 3, 2012
  35. San Francisco Chronicle, "Editorial: Chronicle recommends", October 5, 2012
  36. [ San Jose Mercury News, "Summary of our endorsements on state propositions", September 22, 2012]
  37. Santa Cruz Sentinel, "Prop. 32: Unfair, and flawed Measure would ban using payroll deductions for political purposes", September 22, 2012
  38. Ventura County Star, "Editorial: Prop. 32 a sham, deserves to lose in Nov. 6 election", August 30, 2012
  39. Press Enterprise, "Initiative trails in new poll", September 20, 2012
  40. Public Policy Institute of California, "Californians and Their Government", September 2012
  41. 41.0 41.1 41.2 41.3 Los Angeles Times, "Judge orders changes to Prop. 32 language", August 13, 2012
  42. In the Court of Appeal of the State of California in and for the Third Appellate District, "Kamala D. Harris v. The Superior Court of Sacramento, Respondent, and Debra Bowen, as Secretary, etc., et al., Real Parties in Interest, Filed August 13, 2012
  43. 43.0 43.1 Superior Court of the State of California County of Sacramento, "Lou Paulson v. Debra Bowen"

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