California, United States of America
The following excerpt is from W. W. Dean & Associates v. City of South San Francisco, 190 Cal.App.3d 1368, 236 Cal.Rptr. 11 (Cal. App. 1987):
The majority recognizes that generally an amendment to a legislative act is a legislative act, but appears to state when the modification is minor it will not be considered a legislative act and cites Fishman v. City of Palo Alto (1978) 86 Cal.App.3d 506, 511, 150 Cal.Rptr. 326, as authority for this proposition. In Fishman the court found that the modification of development plans "did not amount to a substantial alteration" of the plans. (Id., at pp. 511-512, 150 Cal.Rptr. 326.) However, in so finding the court in Fishman stated: "Some changes in the development plan of a planned community district may well be legislative and subject to referendum. That determination must be made on a case-by-case basis." (Ibid.)
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