Abstract
unusually broad and well-entrenched in California. As a result of that right, residents of that state have employed both of these tools of direct democracy to manage local growth. In this article the initiative will be treated as the power of voters to draft and implement growth control measures within local governmental settings. The local growth control referendum will, in turn, represent their power to rescind local governmental actions that fail to promote a desired level of growth control. This article describes how courts in California have developed a body of case law governing such local efforts to control growth by direct legislation.
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