The Bluebook lacks specific rules for citing to state ballot initiatives such as propositions, referenda, or recall elections. The following limited guidance draws on the existing Bluebook rules to suggest the preferable sources and citation formats to apply.
An approved proposition becomes part of codified law and should usually be cited per Rule 11 (constitutions) or Rule 12.4 (codified statutes). Similarly, an approved referendum either repeals (in the case of vetoing referendum) or provides the effective date of (in the case of a ratifying referendum) statutory or constitutional provision(s) codified by legislative enactment, so the law itself should be cited per Rule 11 or Rule 12.4, with a parenthetical noting repeal (and including proposition number and date of the referendum, if relevant) or noting (if relevant) the effective date (and including proposition number and date, if relevant).
For rejected propositions and referenda, or for approved measures in circumstances in which session laws rather than code should be cited (see Rule 12.2), cite to the proposition using the session laws compilation, Statutes and Amendments to the Code (via Hein Online). Information such as the date and type of election, and the election result, can be included in an explanatory parenthetical.
Other materials associated with a proposition appearing in the ballot (such as the Attorney General's summary, the Legislative Analyst Office analysis, and so on) are not included in the session law compilation, and are best cited to the print version of the ballot (available from the various online and print/microform sources noted in this guide) under Bluebook Rule 15.
Failed or withdrawn propositions are not formally published in print, but are available online, as PDFs, via the sources in this guide, including a governmental website. Rule 18.2.1(b) of the Bluebook provides general guidelines on citation of such materials.
Applying the above principles, here are some examples of possible citations involving ballot initiatives. In these examples it is assumed that there is a reason to cite to the proposition (instead of directly to the affected statutory or constitutional provision) and/or that the ballot initiative process or documents are relevant to the point being supported (such as supporting the historical fact of a referendum challenge).
California Proposition 8 of 2008 (since invalidated by the courts and subsequently repealed by constitutional amendment) could be cited as:
California Marriage Protection Act, 2008 Cal. Stat. A-298 (codified at Cal. Const. art. I, § 7.5 (2008), repealed by Res. ch. 125, 2023 Cal. Stat. A-1 (Assembly Constitutional Amendment 5 (2024) presented to and ratified by voters as Prop. 3 in general election of Nov. 5, 2024)) (Prop. 8 approved by voters in general election of Nov. 4, 2008), invalidated by Perry v. Schwarzenegger, 704 F. Supp. 2d 921 (N.D. Cal. 2010), aff'd sub nom. Perry v. Brown, 671 F.3d 1052 (2012), vacated on other grounds sub nom. Hollingsworth v. Perry, 570 U.S. 693 (2013).
Note: The example includes codification information (per Rule 12.4(f)) with a date parenthetical for the constitutional provision (per Rule 11): "Cite constitutions ... no longer in effect by year of adoption; if the specific provision cited was adopted in a different year, give that year parenthetically." Because that version was invalidated and then repealed, the codification includes a "(2008)" date.
Recycling—Grocery Bags, 2016 Cal. Stat. A-157 (codified as amended at Cal. Pub. Res. Code § 42280 et seq.) (ratified via referendum vote as Prop. 67 in the Nov. 8, 2016 election).
Environmental Protection Fee Act, 2016 Cal. Stat. A-157 (to be codified at Cal. Pub. Res. Code § 42270 et seq.) (presented as Prop. 65, and rejected by voters, in general election of Nov. 8, 2016).
Proposition 25, 2020 Cal. Stat. A-127 (referendum approved Nov. 3, 2020, vetoing Crimes and Offenses—Bail, 2018 Cal. Stat. 2554, ch. 244, to be codified at Cal. Gov't Code § 27771 and Cal. Penal Code §§ 1320.6-.34, including veto of repeal of Cal. Penal Code § 1268 et seq.).