The First Appellate District affirmed an order. The court held that an Elections Code provision that implemented a ballot initiative passed by voters and that precluded candidates from stating on a ballot a preference for a non-qualified political party was constitutional under Libertarian Party of California v. Eu (1980) 28 Cal.3d 535.

Ballot initiative Proposition 14 was approved by voters. Prop 14 replaced qualified-party primaries to select party nominees in the general election with one open primary to select voter-nominated candidates for several state offices, as well as for federal representatives and senators.