California, United States of America
The following excerpt is from Rossi v. Brown, 38 Cal.Rptr.2d 363, 889 P.2d 557, 9 Cal.4th 688 (Cal. 1995):
In Dougherty v. Austin (1892) 94 Cal. 601, 29 P. 1092, a statute authorized a county board of supervisors to hire a deputy county clerk whenever it deemed the county clerk to be insufficiently compensated. We held the statute violated the constitutional prohibition against increasing the compensation of county officers during their term of office. (Cal. Const., former art. XI, 9.) We reasoned, "To construe this provision of the constitution so that a county clerk's salary could not be increased during his term of office, but that an act of the legislature would be valid which provided that all of his deputies, men whom he was bound to employ and bound to pay in the absence of such an act, should be paid by the county, independent of and in addition to the clerk's salary, would be to allow that to be done indirectly which could not be done directly, and would be establishing a medium for the practice of the very abuses which the constitutional provision was inserted to destroy." (94 Cal. at p. 632.)
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