The California Supreme Court denied a petition for writ of mandate and/or prohibition. The court held that the state senate district map certified by the Citizens Redistricting Commission should continue to be used until such time that a pending referendum measure challenging the map was voted on by California voters.

In 2008, California voters approved an amendment to the state constitution removing the task of redistricting from the Legislature and giving it to the newly created Citizens Redistricting Commission (CRC). Article XXI, § 1 required the CRC to adjust the boundary lines of the state senate, state assembly, congressional, and State Board of Equalization voting districts “[i]n the year following the year in which the national census is taken under the direction of Congress at the beginning of each decade ….” In August 2011, after extensive review and revision, the CRC approved and certified all four required maps.