1 Mark Peterson

State Bar No. 111961

2 5405 Oakstone Court
Concord, California 94521
3 (925) 890-4600 (Cellphone)
(925) 686-3422 (Home)
4 markdda@aol.com
5

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IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
7
IN AND FOR THE COUNTY OF CONTRA COSTA
8

9 MARK PETERSON, ) Case No.:

Petitioner, )
10 v. ) POINTS AND AUTHORITIES IN
11 ) SUPPORT OF PETITION FOR
STEPHEN WEIR, ) WRIT OF MANDATE TO COMPEL
12 as Registrar of Voters ) ACCEPTANCE OF ACCEPTABLE
of the County of Contra Costa, ) BALLOT DESIGNATION
13 ) (Elec. Code, §§ 13107, 13314.)
Respondent, )
14 )
WILLIAM DAN O‟MALLEY, and ELLE FALAHAT, )
15 )
Real Parties in Interest. ) Date:
16 ) Time:
17 ) Dept:

18
I.
19
STATEMENT OF FACTS AND
20
STATEMENT OF THE CASE
21

22 In response to an informal, non-judicial challenge lodged by Candidate O‟Malley, Registrar Weir

23 has refused Candidate Peterson‟s request to use Assistant District Attorney as his ballot designation.
24 Yet in his own campaign materials in the upcoming election, Candidate O‟Malley repeatedly describes
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 1 himself as a former Assistant District Attorney. (Candidate Peterson does not allege that Candidate

2 O‟Malley is engaged in excessive hypocrisy, but rather, this is compelling evidence that the terms
3 Assistant District Attorney and Deputy District Attorney both fairly and accurately reflect the profession
4
that both candidates practiced, at various points in their respective careers, while working as criminal
5
prosecutors here in Contra Costa County. They each shared the same job title and the same job
6
classification.) In two previous elections – in both the primary and in the general election in 2002 –
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Registrar Weir permitted another candidate for District Attorney – Mike Menesini – to use Assistant
8
District Attorney as his ballot designation. This was because Candidate Menesini worked in exactly the
9
same capacity as Candidate Peterson currently does, and as Candidate O‟Malley did in the past, i.e. as a
10

11 criminal prosecutor.

12 The phrases Assistant District Attorney and Deputy District Attorney are each commonly used

13 phrases, both accurately describing a subordinate prosecutor who assists the elected District Attorney in

14 prosecuting criminal cases. Some California prosecutors are designated as assistant district attorneys;
15 others are designated as deputy district attorneys. Registrar Weir refuses to permit Candidate Peterson
16
to use Assistant District Attorney as his ballot designation, for the following stated reason: “According
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to Contra Costa County Human Resources Department records, [Candidate Peterson‟s] job classification
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and title is „Deputy District Attorney – Advanced‟ (Job Classification and Title 2KTG). According to
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Human Resources Department records, the job classification and title of „Assistant District Attorney‟
20
(Job Classification and Title 2KD3) is a job title and classification separate from „Deputy District
21
Attorney.‟”
22

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 1 Candidate Peterson challenges Registrar Weir‟s erroneous refusal to accept his ballot designation

2 of Assistant District Attorney. Elections Code section 13314(a)(1) authorizes Candidate Peterson to
3 challenge Registrar Weir‟s erroneous refusal to accept Assistant District Attorney.1
4

5 II.

6 ARGUMENT

7 A WRIT OF MANDATE SHOULD ISSUE,

8 COMPELLING REGISTRAR WEIR TO ACCEPT CANDIDATE PETERSON’S

SUITABLE AND DESCRIPTIVE BALLOT DESIGNATION
9

10

11 1. California Law Prohibits Registrar Weir From Refusing Candidate Peterson’s Suitable,

12 Descriptive, Non-Misleading Ballot Designation

13
California law permits Candidate Peterson to use Assistant District Attorney as his ballot
14
designation, because it is not misleading, as contemplated by Elections Code section 13107(b)(1).
15
The governing statute does not require the most specific job description available, but merely one
16
which is serviceable. The statute does not require that candidates list their specific job titles, as
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designated by their employers. It only requires that the ballot designation describe the candidate‟s
18

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20 1 “The action or appeal [challenging a ballot designation] shall have priority over all other
21 civil matters.” (Elec. Code, § 13314, subd. (a)(3), emphasis added.) Unless this court expedites this

22 matter for a hearing and for resolution, Registrar Weir will print and distribute ballots and voter
pamphlets and candidates‟ statements containing the challenged materials, before Candidate Peterson is
23
afforded an opportunity to be heard on this matter, so that the lawful issuance of the writ otherwise
24
might interfere with the printing or distribution of official election materials as provided by law.
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 1 vocation, profession, or occupation in a way that does not mislead the voter. (Elec. Code, § 13107,

2 subd. (b)(1).) Candidate Peterson wishes to use Assistant District Attorney as his ballot designation
3 because, in this age of mass media and television, that phrase is much more familiar to the electorate
4
than the less well recognized “Deputy District Attorney.”
5
Elections Code section 13107(a)(3) “requires that the ballot designation reflect the candidate‟s
6
„principal professions, vocations, or occupations . . .‟” (Andal v. Miller (1994) 28 Cal.App.4th 358,
7
366; Cal. Code Regs., tit. 2, § 20710, subd. (a).)2 “[I]immediately under the name of each candidate,
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and not separated from the name by any line, may appear at the option of the candidate . . . the
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following designation[ ]: [¶] No more than three words designating either the current principal
10

11 professions, vocations, or occupations of the candidate, or the principal professions, vocations, or

12 occupations of the candidate during the [preceding] calendar year . . .” (Elec. Code, § 13107, subd.

13 (a)(3).)

14 California law requires that a ballot designation describe the candidate‟s profession or
15 occupation in a way that does not mislead the voter. (Elec. Code, § 13107, subd. (b)(1); accord, Rubin v.
16
City of Santa Monica (9th Cir. 2002) 308 F.3d 1008, 1011-1012.) “Neither the Secretary of State nor
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any other elections official shall accept a [ballot] designation . . . which [¶] . . . would mislead the
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19

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21 2 “The regulatory purpose of this Chapter [Cal. Code Regs., tit. 2, chap. 7 (“Ballot
Designations”)] is to ensure the accurate designation of the candidate upon the ballot in order that an
22
informed electorate may intelligently elect one of the candidates.” (Cal. Code Regs., tit. 2, § 20710,
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subd. (a).)
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 1 voter.” (Elec. Code, § 13107, subd. (b)(1).) The “regulations further an important governmental

2 interest, . . . they are non-discriminatory, are viewpoint-neutral, and . . . they do not severely limit a
3 candidate‟s First Amendment rights.” (Rubin v. City of Santa Monica, supra, 308 F.3d at p. 1019.)
4
The guidelines “provide . . . objective standards for the election officials who are called upon to
5
approve or disapprove ballot designations.” (Luke v. Superior Court, supra, 199 Cal.App.3d at p. 1363,
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italics added.) “These nondiscriminatory regulations are reasonably related to the legitimate goal of
7
achieving a straightforward, neutral, non-confusing ballot.” (Rubin v. City of Santa Monica, supra, 308
8
F.3d at p. 1017.) “The regulations . . . provide guidance in determining what qualifies for an occupation
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and limit the discretion of election officials by providing relatively concrete standards. Asking election
10

11 officials to make [an] open-ended and ultimately subjective determination [that a proposed designation

12 actually is misleading] would inevitably introduce additional uncertainty and bias into the approval

13 process as well as invite additional judicial intervention.” (Rubin v. City of Santa Monica, supra, 308

14 F.3d at pp. 1018-1019, citing Luke v. Superior Court, supra, 199 Cal.App.3d at p. 1363.) In the case
15 before this court, Registrar Weir has made an open-ended and ultimately subjective determination that
16
the proposed ballot designation is misleading, without any support in the underlying statute or
17
regulations.
18
The Secretary of State‟s regulations support Candidate Peterson‟s lawful right to designate
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himself as an Assistant District Attorney. “The terms „profession,‟ „vocation,‟ or „occupation,‟ as those
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terms are used in Elections Code § 13107[(a)(3)], are defined as follows: [¶] „Profession‟ means a field
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of employment requiring special education or skill and requiring knowledge of a particular discipline . . .
22

23 Examples of an acceptable designation of a „profession,‟ as defined in Elections Code § 13107,

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 1 subdivision (a)(3), include, but are not limited to, „attorney,‟ „physician,‟ [etc.] . . .” (Cal. Code Regs.,

2 tit. 2, § 20714, subd. (a)(1)).) “„Occupation‟ means the employment in which one regularly engages or
3 follows as the means of making a livelihood.” (Cal. Code Regs., tit. 2, § 20714, subd. (a)(3).)
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Assistant District Attorney accurately describes Candidate Peterson‟s principal profession or
5
occupation. Although Registrar Weir can refuse to accept a misleading ballot designation (Elec. Code,
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§ 13107, subd. (b)(1)), he has no statutory authority to refuse an accurate one, merely because the
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candidate‟s acceptable, serviceable, non-misleading, and generic description of his principal profession
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or occupation happens to overlap with a specific job title that the County of Contra Costa‟s Human
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Resources Department has established. “[T]he Secretary . . . shall reject as unacceptable any proposed
10

11 ballot designation which would mislead voters. In making this determination, the Secretary . . . shall

12 determine whether there is a substantial likelihood that a reasonably prudent voter would be misled as to

13 the candidate‟s principal profession, vocation or occupation by the candidate‟s proposed ballot

14 designation.” (Cal. Code Regs., tit. 2, § 20716, subd. (c).) The average, reasonably prudent voter in
15 Contra Costa County ascribes the well-established, plain meaning to the phrase Assistant District
16
Attorney, i.e., it describes someone who prosecutes criminals for a living. The average, reasonably
17
prudent voter in Contra Costa County has no idea that the County‟s Human Resources Department has
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established a job classification and title of Assistant District Attorney, separate and apart from its
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establishment of the job title and classification of Deputy District Attorney.
20
The requested ballot designation, moreover, is not misleading when read in conjunction with
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Candidate Peterson‟s candidate statement. Nowhere does he allege that he is the Assistant District
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23 Attorney, as designated by the Human Resources Department. Rather, in his candidate statement, he

24 begins, “As an Assistant District Attorney . . .” The voters are presumed to know the law. (Cf. People

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 1 v. Wheeler (1992) 4 Cal.4th 284, 302 [“the voters intended legal terms to have their legal compass”].

2 The voters presumptively know that the ballot designation refers to the candidates‟ “principal
3 professions, vocations, or occupations” (Elec. Code, § 13107, subd. (a)(3)), not to their specific job
4
titles, as designated by their employers‟ Human Resources Department. Furthermore, Candidate
5
Peterson‟s ballot statement identifies his occupation, not his specific job title, as an Assistant District
6
Attorney; it commences with the subheading, “Occupation: Assistant District Attorney.”
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“The determination [regarding whether a proposed ballot designation violates Elections Code
8
section 13107(b)(1)] shall take into account the plain meaning of the words constituting the proposed
9
ballot designation and the factual accuracy of the proposed ballot designation . . .” (Cal. Code Regs., tit.
10

11 2, § 20716, subd. (c), italics added; see Evid. Code, § 451, subds. (e), (f) [““Judicial notice shall be taken

12 of . . . [¶] The true signification of all English words and phrases and of all legal expressions. [¶] Facts

13 and propositions of generalized knowledge that are so universally known that they cannot reasonably be

14 the subject of dispute”].) The plain meaning of an Assistant District Attorney refers to someone who
15 prosecutes criminals for a living, which is indisputably the profession that Candidate Peterson practices.
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“The assistant district attorney (ADA), or prosecutor, is the local public official who represents the
17
government in the prosecution of alleged criminals. The prosecution is the legal party responsible for
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presenting the case against an individual suspected of breaking the law in a criminal trial.”
19
(http://lawandorder.wikia.com/wiki/Assistant_district_attorney.)
20
Just as issues of statutory interpretation are reviewed de novo (People v. Haykel (2002) 96
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Cal.App.4th 146, 149), so too is Registrar Weir‟s assessment of what would mislead a reasonably
22

23 prudent voter. “[T]he interpretation and applicability of a statute is a question of law.” (City of

24 Petaluma v. County of Sonoma (1993) 12 Cal.App.4th 1239, 1244.) “An abuse of discretion is shown

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 1 when the [entity] applies the wrong legal standard. ([Citation].)” (Cf. Costco Wholesale Corp. v.

2 Superior Court (2009) 47 Cal.4th 725, 764.) An entity exceeds its jurisdiction when a statute authorizes
3 a prescribed procedure, yet the entity acts contrary to the authority thus conferred. (Cf. People v.
4
Superior Court (Marks) (1991) 1 Cal.4th 56, 71, fn. 10; Safer v. Superior Court (1975) 15 Cal.3d 230,
5
242; Judith P. v. Superior Court (2002) 102 Cal.App.4th 535, 551.) Absolutely nothing in Election
6
Code section 13107, nor in the Secretary of State‟s regulations, permits Registrar Weir to refuse an
7
acceptable, accurate, serviceable, and generic ballot designation, merely because the candidate‟s suitable
8
description of his principal profession or occupation happens to overlap with a specific job title and
9
classification established by the Human Resources Department has.
10

11 Registrar Weir suffers under the misconception that because the County of Contra Costa has

12 designated Candidate Peterson‟s current job title and classification as Deputy District Attorney –

13 Advanced, and because the County has endowed another county job classification and title as Assistant

14 District Attorney, Candidate Peterson is precluded from adopting a particular, accurate description of his
15 principal profession or occupation. But the following terms each accurately describe Candidate
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Peterson‟s principal profession or occupation, so that each of them are suitable as a ballot designation:
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Assistant District Attorney, Deputy District Attorney, Attorney, Lawyer, Attorney at Law, Prosecutor,
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Criminal Prosecutor, Felony Prosecutor, Advanced Prosecutor, Crime Fighting Prosecutor, Crime
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Fighting Lawyer, Crime Fighting Attorney, Crime Fighting Litigator, Criminal Attorney, Felony
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Attorney, Criminal Lawyer, Felony Lawyer, Criminal Litigator, Felony Litigator, Homicide Prosecutor,
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Homicide Attorney, Homicide Lawyer, Homicide Litigator, Government Prosecutor, Government
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23 Attorney, Government Lawyer, Government Litigator, Advanced Government Prosecutor, Advanced

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 1 Government Attorney, Advanced Government Lawyer, Advanced Government Litigator, Prosecuting

2 Lawyer, Prosecuting Attorney, Prosecuting Litigator, Litigator, Senior Litigator, Advanced Litigator,
3 Crime Fighting Litigator, Trial Attorney, Trial Lawyer.
4
Each of those terms accurately and suitably describe Candidate Peterson‟s principal profession or
5
occupation. The fact remains, however, that in this age of electronic media, where Law and Order has
6
saturated the prime time airwaves for nearly 20 years, Assistant District Attorney is the term that most
7
accurately and suitably describes his principal profession or occupation in a manner most readily
8
understood and appreciated by the vast majority of the electorate. The County‟s arbitrary job
9
classifications and titles can no more preclude him from using that term, than could the County prevent
10

11 him from using Litigator, Government Attorney, Government Lawyer, Government Litigator, Advanced

12 Litigator, Trial Attorney, or Trial Lawyer, if the County already had designated those terms as job

13 classifications and titles for those employed in the Office of County Counsel. The statute does not

14 require that Candidate Peterson use the County‟s job classification and title. Nor can pre-existing job
15 classifications and titles prevent him from designating his principal profession or occupation, accurately,
16
in a manner most readily understood and appreciated by the vast majority of the electorate.
17
The statute does not require the most specific job description available, nor does it prohibit well-
18
established, appropriate descriptions of one‟s principal profession or occupation. The statute merely
19
requires a designation which is serviceable or suitable. In Andal v. Miller (1994) 28 Cal.App.4th 358,
20
the court took a similar view. The Andal candidate‟s opponent argued that Peace Officer was
21
misleading as a ballot designation because it encompassed “too broad a category, encompassing as it
22

23 does everyone from the Attorney General to the local litter control officer.” (Id., at p. 365.) The Andal

24 court responded as follows:

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 1

2 “But as counsel for the Secretary of State correctly observes, there is nothing
in [Election Code section 13107‟s statutory predecessor] which mandates the
3
selection of the more specific over the more general, so long as the designation
4
chosen does not mislead the voters. „The term „businessman,‟ counsel notes, „could
5 encompass anything from a door-to-door magazine salesman to the president of IBM,
6 but it is routinely accepted as a ballot designation without the requirement of further
elaboration.‟ Just as the president of IBM could select the designation „businessman,‟
7
so too could a regular deputy sheriff use „peace officer.‟ Accordingly, we hold that
8
the position of a paid „peace officer‟ is a profession, vocation or occupation within
9 the meaning of [Election Code section 13107‟s statutory predecessor].” (Andal v.
10 Miller, supra, 28 Cal.App.4th at p. 365.)

11
The statute only requires that the ballot designation describe the candidate‟s vocation, profession,
12
or occupation in a way that does not mislead the voter. (Elec. Code, § 13107, subd. (b)(1).) The Andal
13

14 court decided that a generic description is not misleading. This is consistent with the limited purpose of

15 the ballot designation – to identify the candidate‟s principal profession or occupation. If this court were

16 to accept the claim that generality is misleading, or that a widely accepted and understood phrase is

17 misleading because it overlaps with a particular job title and classification, it would engender an endless
18 number of highly subjective controversies concerning what is required to specifically describe the
19
myriad of professions and occupations in our society. (See, e.g., Luke v. Superior Court (1988) 199
20
Cal.App.3d 1360, in which the trial court permitted a court commissioner to use the term Acting Judge
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because Commissioner was believed to be unfamiliar to the electorate; see also Rubin v. City of Santa
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 1 Monica, supra, 308 F.3d at pp. 1018-1019 [asking election officials to make an open-ended and

2 ultimately subjective determination, untethered to the Secretary‟s underlying regulations, would

3 introduce excessive uncertainty and bias into the approval process].)
4
Candidate O‟Malley presumably describes himself repeatedly as a former Assistant District
5
Attorney, on his campaign websites, because that phrase is the one most familiar to the electorate.
6
Contra Costa County‟s media market is served extensively by the San Francisco Chronicle, which
7
routinely describes prosecutors as Assistant District Attorneys – the term used throughout San
8
Francisco. Candidate Peterson is routinely asked, “Are you an Assistant District Attorney?,” and he
9
routinely responds in the affirmative, because it is a colloquialism that is commonly understood, by the
10

11 public, to accurately describe the profession and occupation that he has engaged in for the past 25 years.

12 In this age of television, the viewing public associates Assistant District Attorneys with those

13 who prosecute crime. “Law & Order is a legal drama that airs on NBC. Law & Order premiered on

14 September 13, 1990, and is currently in its twentieth season, which began airing on September 25, 2009.
15 Law & Order is currently the longest running crime drama on American prime time television and is
16
tied for longest running drama with Gunsmoke. It was renewed for a 21st season.” (http://en.wikipedia
17
.org/ wiki/Law_&_Order.) For the past 20 years, the most popular crime drama on television has
18
described the profession and occupation of those engaged in the prosecution of crime as Assistant
19
District Attorneys. “The assistant district attorney (ADA), or prosecutor, is the local public official who
20
represents the government in the prosecution of alleged criminals. The prosecution is the legal party
21
responsible for presenting the case against an individual suspected of breaking the law in a criminal
22

23 trial.” (http://lawandorder.wikia.com/wiki/Assistant_district_attorney.) Similarly, “Sylvia Costas-

24 Sipowicz. . . [was an] Assistant District Attorney [married to] Detective Andy Sipowicz [on the crime

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 1 drama, NYPD Blue].” (http://en.wikipedia.org/ wiki/Sylvia_Costas.) Candidate Peterson is unaware of

2 any television series that currently uses the term Deputy District Attorney, and even if they exist, they
3 certainly have not exercised the significant cultural impact upon the electorate as that exercised by Law
4
& Order and by NYPD Blues during the past two decades.
5
An entire online article exists for career aspirants who wish to become prosecutors. It is entitled,
6
“Guide to a Career as an Assistant District Attorney.” (http://www.associatedcontent.com/article
7
/74018/guide_to_a_career_as_an_assistant_district.html.) It states, “Assistant district attorneys are
8
judicial employees (sic.) who work for the District Attorney‟s office in a particular state or region.
9
Assistant district attorneys are responsible for indicting criminals and prosecuting them in court.” (Ibid.)
10

11 Thousands and thousands of criminal prosecutors, throughout this nation, practice the profession of an

12 Assistant District Attorney. It is such a well recognized profession that an entire online article is

13 devoted to those who wish to join the profession‟s fellowship. Candidate Weir has absolutely no legal

14 authority for denying Candidate Peterson his proposed ballot designation, where Candidate Peterson is
15 one of the thousands of attorneys who has earned the right, and the privilege, to practice the profession
16
of an Assistant District Attorney. A Deputy District Attorney‟s principal profession is equivalent to an
17
Assistant District Attorney‟s principal profession, and the former can seek election under the latter
18
designation, just as an Administrative Assistant can run for public office with a ballot designation of
19
Secretary or Executive Assistant. The arbitrary delineations of an employer‟s job classifications and
20
titles cannot control.
21
Furthermore, Assistant District Attorney accurately describes Candidate Peterson‟s principal
22

23 profession and occupation from a linguistic standpoint. The dictionary defines an assistant as one

24 “[h]olding an auxiliary position; subordinate.” (http://education.yahoo.com/reference/dictionary

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 1 /entry/assistant.) And while the dictionary describes a deputy as “a second in command or assistant who

2 usually takes charge when his or her superior is absent; specifically: DEPUTY SHERIFF” (http://
3 dictionary.reference.com/browse/deputy), the term deputy is more likely to conjure up, in the average
4
voter‟s mind, the image of a deputy sheriff, as opposed to that of a criminal prosecutor. Under the
5
online Law Dictionary definition of District Attorney, it states, “A district attorney will frequently have
6
assistants who are similarly empowered.” (http://www.answers.com/topic/district-attorney.) The two
7
designations – ADA‟s and DDA‟s – can be used interchangeably. “The district attorney is the highest
8
officeholder in the jurisdiction‟s legal department and supervises a staff of assistant (ADA) or deputy
9
district attorneys.” (http://en.wikipedia.org/wiki/District_attorney.)
10

11 Since Assistant District Attorney suitably describes Candidate Peterson‟s current profession or

12 occupation, and since that term‟s well-established meaning precludes it from being misleading, as a

13 matter of law, for purposes of Elections Code section 13107, this court should issue a writ of mandate

14 commanding Registrar Weir to accept it.

15

16

17
III.
18 CONCLUSION
19
Registrar Weir has acted upon Candidate O‟Malley‟s informal challenge to Candidate Peterson‟s
20
suitable description of his principal profession. Registrar Weir has done so, despite the fact that
21
Candidate O‟Malley impliedly admits – by his very own conduct, earlier in this election – that Assistant
22
District Attorney suitably describes Candidate Peterson‟s current profession.
23

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 1 Accordingly, this court should issue a writ of mandate directing Registrar Weir to correct his

2 legal error. It should compel Registrar Weir to accept the descriptive ballot designation that suitably

3 describes Candidate Peterson‟s current profession. Assistant District Attorney accurately describes his

4 current profession; the term‟s well-established meaning precludes it from being misleading, as a matter

5 of law, for purposes of Elections Code section 13107.

7
Dated: March 22, 2010 Respectfully submitted,
8

9
__________________________
10 Mark Peterson
Petitioner
11 Candidate for District Attorney
Attorney at Law
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