UHLER Et Al. v. AMERICAN FEDERATION OF LABOR-CONGRESS OF INDUSTRIAL ORGANIZATIONS Et Al.

Background

Supporters sought to place a ballot initiative in California that would push the State Legislature, or the Secretary of State if the legislature did not act, to ask Congress to call a Constitutional Convention to require a balanced federal budget. The initiative backers asked a Justice of the Supreme Court to stay (pause) a mandate from the California Supreme Court that had barred the measure from the November 1984 ballot. Labor groups led by the AFL-CIO sued in California, challenging the initiative under both California law and the U.S. Constitution.

Reasoning

The California court raised two federal questions about whether the word “Legislatures” in Article V of the U.S. Constitution includes voter initiatives or legislatures compelled by initiatives. The California court answered “no” but, more importantly, held on independent state-law grounds that key parts of the proposal were not valid “statutes” under California law but were instead “resolutions,” and so could not be enacted by initiative. The Justice reviewing the stay request concluded that the state-court ruling rested on an adequate and independent state ground, and that the applicants’ argument that the matter is a non-justiciable “political question” did not present a substantial federal issue.

Real world impact

The stay was denied, keeping the California court’s ban in place so the initiative could not appear on the 1984 ballot. The Justice emphasized that when a state court’s decision rests on independent state law, federal courts generally will not intervene, and that the broad political-question argument was unlikely to overcome that rule.