In 2015, the California Legislature attempted to address the issue of low voter turnout in off-cycle elections through the California Voter Participation Rights Act (“CVPRA”), which restricts cities from holding off-cycle local elections if they result in low voter turnout. Dozens of cities subsequently changed the dates of their local elections in order to comply with the new law. In the years immediately following the shift, many cities experienced significant increases in voter turnout, with many seeing turnout in the new on-cycle elections that was more than triple the turnout in the off-cycle election preceding the switch. However, in 2020, the Second District Court of Appeal held in City of Redondo Beach v. Padilla that the CVPRA does not apply to charter cities. As a result, the 121 charter cities throughout California remain free to hold off-cycle elections, regardless of turnout.

This Note argues that the California Legislature can constitutionally enact legislation to apply the CVPRA to charter cities. It further argues that the Legislature should extend the CVPRA to charter cities in order to advance important policy outcomes.