Proposition 14
California's Top-Two Nonpartisan Primary
IVP authored the ballot measure that replaced California's closed partisan primaries with a nonpartisan Top Two system — giving every voter access to every candidate on a single ballot.
California's primaries used to serve the parties, not the voters.
Before 2010, California ran a closed partisan primary system. If you were registered as an independent — no party preference — you were effectively locked out of the most consequential stage of the election. In many districts, the primary was the only election that mattered because general elections were predetermined by partisan gerrymandering.
The result was a system where roughly 5 million independent voters in California had no meaningful voice in choosing their representatives. Candidates only had to appeal to their partisan base, producing some of the most polarized legislatures in the country.
IVP's response was Proposition 14 — a ballot measure that fundamentally restructured how California runs primary elections. Instead of separate party primaries, all candidates would appear on a single ballot regardless of party affiliation, and all registered voters could participate. The top two vote-getters would advance to the general election.
Author it. Pass it. Defend it.
IVP didn't just advocate for Proposition 14 — IVP authored it. Working with a bipartisan coalition of reformers, IVP crafted the ballot language, built the legal framework, and drove the effort that would put it before California voters.
The opposition was immediate and fierce. Both major parties fought the measure, joined by third-party organizations who argued it would eliminate their candidates from general election ballots. Despite that opposition, California voters passed Proposition 14 in the June 2010 primary election.
But passing the ballot measure was only the beginning. Partisan interests immediately filed federal lawsuits to overturn the results. IVP anticipated this and had already prepared the constitutional defense — launching a multi-year legal effort that would culminate in three landmark federal court victories.
The Road to Reform
Proposition 14 Filed
IVP authors and files the ballot measure to establish a nonpartisan Top Two primary system for all California state and congressional elections.
Passed by California Voters
Despite organized opposition from both major parties and third-party organizations, Proposition 14 passes with 54% of the vote.
First Legal Challenge Filed
Partisan interests file suit in federal court to overturn Proposition 14, arguing it violates party association rights. IVP leads the legal defense.
First Top Two Primary Election Held
California holds its first nonpartisan primary under Proposition 14. All voters — including 5+ million independents — participate on a single ballot.
Boden v. Secretary of State — Won
The federal court upholds Proposition 14's constitutionality, establishing precedent that states can adopt nonpartisan primary reforms.
Rubin v. Bowen — Won
A second federal challenge is defeated. The court rules that voter participation rights outweigh partisan ballot access claims.
Nearly 40 Million Voters Protected
Proposition 14 remains the most significant structural election reform in modern California history. The legal precedent IVP established now serves as a framework for reform efforts nationwide.
What Proposition 14 Changed
Nearly 40 million Californians now participate in a primary system that doesn't require party membership.
Every Voter, One Ballot
All registered voters — regardless of party affiliation — participate in the same primary on the same ballot.
Competitive General Elections
By advancing the top two candidates, districts that were once uncontested now have meaningful general election races.
Constitutional Precedent
Three federal court victories established durable legal precedent that other states can build on for nonpartisan primary reform.
National Blueprint
Proposition 14 created the legal and political playbook now being used to advance open primary reforms across the country.
“When every voter has a voice in every election, candidates have to earn their support from the broadest possible electorate — not just their partisan base. That's what Proposition 14 delivered.”
— Independent Voter ProjectRelated Cases
Boden v. Secretary of State
After Proposition 14 passed, partisan interests immediately challenged it in federal court. IVP led the legal defense to protect the nonpartisan primary from being struck down.
Read the Full CaseThe court upheld the constitutionality of the Top Two system, establishing legal precedent that states can adopt nonpartisan primary reforms without violating party association rights.
Rubin v. Bowen
A second federal challenge targeted the Top Two primary, arguing it unconstitutionally burdened minor parties' access to the general election ballot. The court ruled that voter participation rights outweigh partisan ballot access claims.
Read the Full CaseThe ruling reinforced that the Top Two primary serves a compelling state interest in opening elections and that the rights of voters to participate outweigh partisan ballot access claims.
Boydston v. Padilla
IVP challenged the state of California over the exclusion of independent voters from presidential primaries — arguing that taxpayer-funded elections must be open to all taxpayers.
Read the Full CaseThe court deferred to party autonomy for presidential primaries, and SCOTUS denied certiorari in October 2023 (144 S.Ct. 496). The case raised national awareness of the contradiction: voters fund elections they can't vote in.
Every reform starts with someone writing the law.
IVP authors ballot measures, qualifies them, and defends them in court. Your donation funds the next initiative: from draft language to the ballot box.