St. John's Well Child & Family Center v. Schwarzenegger

Summary

The California Supreme Court considered whether the Governor exceeded his authority under article IV, section 10(e) of the California Constitution by further reducing appropriations after the Legislature had enacted midyear budget reductions. The court upheld the Governor's line-item reductions and denied the petition for a writ of mandate. The opinion analyzes the meaning of an "item of appropriation" and relies substantially on Wood v. Riley and Harbor v. Deukmejian.

Holdings

1. A legislative provision that specifies a definite reduction to an appropriation for a designated governmental purpose is itself an item of appropriation subject to the Governor's authority to reduce or eliminate it under article IV, section 10, subdivision (e) of the California Constitution.
2. The Governor may exercise line-item authority over appropriations that the Legislature has amended or reduced after the original budget enactment; the Governor is not limited to a single opportunity to reduce an appropriation when it is first enacted.
3. The Governor's further reductions did not violate separation of powers because article IV, section 10(e) expressly authorizes the Governor to exercise this limited legislative power.

Questions Presented

1. Whether legislative provisions reducing appropriations previously enacted in the 2009 Budget Act constitute items of appropriation under article IV, section 10, subdivision (e) of the California Constitution.
2. Whether the Governor may use line-item authority to further reduce appropriations that the Legislature has already reduced in a subsequent budget amendment.
3. Whether the Governor's further reductions violated the separation-of-powers provision of article III, section 3 of the California Constitution.

Disposition

affirmed