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California proposition thirty seven: implications for genetically modified food labeling policy.


The process of genetic modification, defined as "any change to the heritable traits of an organism achieved by intentional manipulation" (Health Canada, 2003), has been characterized by heated debate since genetically modified organisms were first introduced in the manufacture of medicinal products in the 1980s. Genetic modification of food and food products further intensified the debate surrounding genetic modification. Food's far-reaching impact and the broad need to fulfill human and livestock nutritional requirements ensure the debate will engender critical interest on both sides of the issue. In turn, the controversy about the genetic modification of food has spawned differing views regarding labeling policies for genetically modified (GM) foods. This debate regarding GM food labeling policy has brought about a divide over GM food labeling requirements between proponents and opponents of GM foods, including governments, individual companies and activist groups (Ho, Vermeer, & Zhao, 2006).

Underlying the GM food labeling debate is the fact that the primary objective of GM labeling is to provide consumer information, not food safety (Gruere & Rao, 2007). The rationales supporting the provision of consumer information differ depending on the type of regulation adopted. Significant debate has addressed whether GM food labeling supports the principle of consumer autonomy (White & Veeman, 2007). Labeling policies focused on production process are supported by the belief that purchase decisions are based, not only on product related issues, but on environmental, religious or ethical concerns (Gruere & Rao, 2007).

National policies regarding GM food labeling fall largely into one of two camps: mandatory labeling of GM products or voluntary labeling of non-GM products. The United States and Canada have adopted a policy of voluntary labeling of non-GM products while the European Union, Japan, Russia, and Australia have endorsed the mandatory labeling of GM products (Gruere, Carter, & Farzin, 2009).

California Proposition thirty seven represents one of the first and certainly one of the most substantial challenges to current United States policy regarding GM food labeling. The measure mandates that all processed foods which contain genetically modified ingredients sold at retail in California be labeled. In addition, all raw fruits and vegetables with genetically modified origins will also be required to be labeled either on the packaging or the shelving where the product is displayed. Proposition thirty seven does offer several prominent exceptions to the mandate. Among these are prepared foods sold at retail establishments or in restaurants, all alcoholic beverages, and any meats, poultry, and dairy foods (California Secretary of State, 2012).

This study consists of four major components. The first part of the literature review examines the scope of global trends in government-mandated GM food labeling policies while the second offers a discussion of the advantages and disadvantages of mandatory GM food labeling policies that have been developed in the academic literature. The third section of this paper specifically examines the content of California Proposition thirty seven followed by an analysis of the recent election results. Finally, the paper discusses the implications of Proposition thirty seven on United States policies on the labeling of GM foods.


Global Trends in GM Labeling Policy

The prevailing divide regarding GM food labeling policy between those countries which require mandatory labeling and those which have adopted a voluntary labeling policy can be traced back to the initial commercialization of GM food technology in the early and mid-1990s. Over the intervening years, more than 40 countries have adopted labeling requirements for GM food and these policies largely reflect the opening positions of the two contrasting parties--the United States and the European Union (Gruere, Carter, & Farzin, 2009).

In the United States, the Food and Drug Administration ruled in 1992 that the emerging GM foods were "substantially equivalent" to their non-GM predecessors and thus not subject to labeling requirements or regulation (Pollan, 2012). However, the underlying technology behind GM food technology was deemed to be unique and subject to patent protection. Thus, in the United States a policy developed which separated the process of GM technology from the actual product itself (Siipi & Uusitalo, 2011). By way of contrast, in a 2001 ruling the Food and Drug Administration allowed for the voluntary labeling of organic and natural foods--in effect, logically combining the process and the product but only for non-GM products. Canadian policy regarding GM food labeling has evolved along similar lines, offering a marketplace where there are no mandatory requirements for the labeling of foods containing GM ingredients but where the voluntary labeling of non-GM foods is allowed (Gruere, Carter, & Farzin, 2008). The net effect of this policy has resulted in a marketplace in which GM foods are widely available yet awareness on the part of the consumer that the foods that they are purchasing have been genetically modified is relatively low (Premanandh, 2011).

On the other hand, the European marketplace for GM food evolved in a completely different manner. Unlike the United States, the European Union (EU) adopted a relatively cautious stance regarding the emerging GM food technology and implemented a moratorium on the production and distribution of new GM products coupled with a mandatory requirement that existing GM food products be labeled (Carlsson, Frykblom, & Lagerkvist, 2007). The imposition of this EU ban on the distribution of new GM foods applied, of course, to imported products as well and served as the impetus for a challenge to the policy by the major exporters of GM based grains and crops. The United States, together with Canada and Argentina, filed a complaining action with the World Trade Organization in 2003 holding that the EU moratorium on newly developed GM products was a violation of previous free trade agreements and amounted to an illegal restraint of trade. In response, the EU then adopted a mandatory labeling policy requiring that any food product containing in excess of 0.9% GM contents be labeled as such (Carlsson, Frykblom, & Lagerkvist, 2007).

In addition, the EU also adopted a process governing the introduction of new GM food products in which approval must be obtained from the European Commission in consultation with the European Food Safety Authority. If approval is given, the new GM food product is then subject to confirmation by a committee of national experts and their respective environmental ministers. If this confirmation is not obtained, the matter of approval then returns to the European Commission for a decision. However, this is not an ultimate decision as each of the individual countries can then over-rule the decision of the European Commission and institute a ban on a national basis (Carlsson, Frykblom, & Lagerkvist, 2007). The net effect of this set of regulatory procedures combined with the mandatory labeling policy in the European Union has resulted in the near absence of GM food products in the retail marketplace (Siipi & Uusitalo, 2011).

Similarly, Russia and much of Eastern Europe have adopted mandatory GM food labeling policies that mirror those of the European Union (Gruere, Carter, & Farzin, 2009). Many researchers have noted the relationship between GM food labeling policies and international trade patterns. Gruere, Carter, and Farzin (2009) noted that major producers of GM crops tend to have less stringent labeling policies more closely resembling the policies of the United States and Canada while major importers of agricultural products tend to have more stringent labeling policies. Consequently, major exporters of agricultural products to the EU have a higher probability of adopting mandatory GM food labeling practices. This can be seen in the relatively more stringent labeling policies in countries such as South Africa, Turkey, Brazil, Australia, and New Zealand.

Countries in Asia appear to be following a similar pattern. Japan was an early adopter of mandatory GM labeling policies, largely as a result of political activism from consumer and farming groups. As of 2001, all products are required to be assessed for GM content before entering the Japanese marketplace and GM labeling is mandatory (Kim & Boyd, 2006). Japan is a major food importer and its consequent trade patterns in agricultural products have resulted in GM labeling throughout much of Asia. China, Japan, Hong Kong, Indonesia, Philippines, South Korea, Taiwan, Thailand, and Vietnam have all adopted GM labeling policies whether mandatory or voluntary (Gruere, Carter, & Farzin, 2009).

Arguments in Favor of Mandatory GM Food Labeling

The arguments in favor of mandatory GM food labeling are largely centered on health-related concerns, environmental concerns, and the rights of consumers to product information. The controversy in Europe, causing store shelves to be void of GM foods (Knight, Mather, & Holdsworth, 2005), arises from consumer fear of the potential negative long term impacts on human health and the environment. From a health perspective, GM foods spark concern over safety, altered nutritional quality, and the possible creation of new viruses and toxins (Azadi & Ho, 2009).

In addition, opponents of GM food production articulate several concerns related to the potential negative impacts on the environment (Azadi & Ho, 2009). Corollary fears include the rise of secondary pests, the increased probability of cross-pollination and/or unintentional gene transfer due to spatial contamination (i.e. lack of sufficient farming acreage dedicated to GM food farming), and difficulty accessing seeds given patenting of GM food plants. In response to claims about safety risks, GM food producers emphasize that GM crops can only be grown after extensive testing and approval and therefore do not present a safety issue for humans, animals or the environment (Premanandh, 2011). In countries with mandatory labeling requirements, GM food producers find themselves confronted by activist groups who launch negative campaigns targeting GM foods and the retailers distributing them. As a result, companies have found it more profitable to avoid GM ingredients altogether, leaving behind a first mover disadvantage, in which a company seeking to market a GM product faces tougher competition from its rivals and high hurdles with consumers (Carter & Gruere, 2003).

To qualm concerns over safety, Premananadh (2011) suggests the development of unified traceability systems, such as the system which led to the recall of Coca-Cola bottles in Belgium with high levels of bromate. Such an infrastructure would eventually deter debatable scientific claims of safety risks, promote consumer confidence, support further development of GM food technology, and ultimately achieve global hunger alleviation with widespread acceptance and use of GM technology. As one study asserts, consumers across the globe are sending a strong message that they may only accept mandatory process-based (traceability) systems (Souza, Rugimbana, Quazi, & Nanere, 2008).

While these approaches to GM food risk management have promise, the outcomes in Europe and other regions suggest that GM food labeling is not the best solution to provide consumer choice or consumer information for it ultimately takes away the consumers' choice and leads to the elimination of GM foods at the retail level. Producers and retailers have experienced a significant loss in sales as a result of the negative reputation of GM foods (Gruere & Rao, 2007) despite the absence of convincing evidence that GM foods are harmful to humans or the environment. Chang (2007) found that product market share decreased by 2 percent after the imposition of labeling in China. In addition, labeling results in an additional cost of up to 30 percent owing to segregation and identity preservation requirements and expensive genetic testing to ensure labeling thresholds (Premanandh, 2011). Furthermore, testing and detection methods suffer from limitations, including deficiencies in reporting on certain types of food components, which inhibits reliable disclosure of GM ingredients. In addition, sample testing of larger quantities has proven unrepresentative (Weighardt, 2006), creating more uncertainty and confusion over GM foods.

Arguments Against Mandatory GM Food Labeling

The arguments against mandatory labeling of GM foods are largely based on the decrease of consumer food options, higher consumer costs, inefficiencies in the international trade of food and agricultural products, and the higher costs of regulation and compliance. While promoting consumer choice through information was the goal of mandatory GM food labeling policies in regions such as the European Union and Japan, these policies have unintentionally resulted in the disappearance of labeled GM food from grocery store shelves (Gruere & Rao, 2007). This outcome stems from the controversy over GM food in Europe and consumer perceptions regarding GM food (Knight, Mather, & Holdsworth, 2005). In turn, European food processors and retailers have avoided using GM ingredients (Kalaitzandonakes, 2004; Kalaitzandonakes & Bijman, 2003) in order to reduce their risk of loss in market share due to consumers' negative attitudes toward GM foods. In sharp contrast, the Food and Consumer Products Manufacturers of Canada (FCPMC) has estimated that in North America sixty to seventy percent of food products on grocery shelves contain GM ingredients. However, consumers in Canada and the United States, while showing a relatively strong consensus favoring GM food labeling, continue to be unaware of goods that contain GM ingredients since labeling requirements remain voluntary (Premanandh, 2011).

While the barriers to GM food market introduction and penetration are high, some researchers assert that proper education and training about GM foods can overcome those hurdles, not only in farming and production, but also in supplying the public with the necessary data to make informed purchases and decisions about consumption (Azadi & Ho, 2009). Education should address the safety concerns of GM foods and the probable augmentation GM would have on global food security, especially for small-scale farming in developing countries (Wisniewski, Frange, Massonneau, & Dumas, 2002). Potentially, GM foods could improve nutritional value and food quality and result in higher crop yields. In addition, GM crops have the potential to lower the overall cost of production given reduced need for chemical fertilizers and pesticides, strengthen drought/frost/salt/pH resistance, and shorten growing duration (Azadi & Ho, 2009).

Azadi and Ho (2009) emphasize that the potential benefits of GM food technology are pervasive, particularly in developing countries where hunger and crop consistency are larger issues than in developed countries. However, the introduction of GM crops in developing countries has been met with resistance. Farmers in developing countries tend to be reluctant to use new technology because the benefits are not always immediately apparent. Also, hesitancy is often expressed by farmers when there is uncertainty regarding product suitability. In other words, will the proposed GM product ultimately alleviate/mitigate the struggles the farmer faces (e.g. drought, crop stability, pests, etc.)? In order to effectively introduce and activate GM food technology in developing (and in developed) countries, Azadi and Ho (2009) believe it is imperative to center efforts on education and training, and ensure that the GM solutions presented accurately address the problems at hand.

The potential benefits of GM food technology are jeopardized by the lack of international consensus for GM food labeling requirements, which has lead to non-compliance by competing countries. This has lead to unfair cost advantages in international markets (Souza, Rugimbana, Quazi, & Nanere, 2008). As a result, some researchers warn that mandatory labeling will act as a trade import barrier, affecting profitability, and ultimately curtailing the widespread adoption of GM food crops (Carter & Gruere, 2003). Moreover, international trade disputes have arisen, particularly between the U.S. and European countries, stemming from the countries' contrasting GM food labeling policies (Souza, Rugimbana, Quazi, & Nanere, 2008).

Some researchers believe that companies, in the absence of mandatory labeling requirements, have no ethical obligation to label GM foods based on three grounds. (MacDonald & Whellams, 2007). First, without a legal standard or government intervention, there lacks a sufficient foundation from which to generate an ethical requirement to labeling. Second, no well-documented danger to human health exists as a result of GM foods. As noted above, Health Canada has declared GM foods to be just as safe as non-GM foods. MacDonald and Whellams (2007) assert that companies have a positive obligation to act only when the health of consumers is at stake. Third, there is no industry consensus as to what standard practice surrounding labeling should be. Given the lack of government intervention, lack of collective action on the part of the industry, and lack of clear evidence of risk to human health, companies cannot be reasonably expected to take unilateral action labeling GM foods, as long as they believe their product poses no threat to the public.


According to the official website of the California Secretary of State, proposition thirty seven would explicitly require the regulation of GM foods sold at retail locations such as grocery stores but not at restaurants. The measure would require that processed foods produced entirely or in part with genetically engineered technology be labeled with the words "Partially Produced with Genetic Engineering" or "May be Partially Produced with Genetic Engineering". Proposition thirty seven also required that raw foods such as fruits and vegetables with GM origins contain the label "Genetically Engineered" on the packaging or if there is no packaging the mandatory label must appear on the shelf where the item is displayed. Furthermore, for each product that is not labeled as GM, a retailer generally must be able to document why that product is exempt from labeling. The measure proposes that there are two primary ways in which a retailer could document that a product is exempt. First, by obtaining a sworn statement from the provider of the product (such as a wholesaler) indicating that the product has not been intentionally or knowingly genetically engineered or, secondly by receiving independent certification that the product does not contain GM ingredients. Other entities throughout the food supply chain (such as farmers and food manufacturers) may also be responsible for maintaining these records (California Secretary of State, 2012).

Proposition thirty seven does include several prominent exemptions. For example, alcoholic beverages such as wine and beer, restaurant food and other prepared foods which are intended to be eaten immediately would not have to be labeled. Animal products, such as beef, dairy products, and poultry that were not directly produced through genetic engineering would also be exempted, regardless of whether the livestock had been fed with GM grain (California Secretary of State, 2012).

Proposition thirty seven offers two modes of enforcement: regulation by the California Department of Public Health and litigation. Violations of the measure could be prosecuted by state, local, or private parties. Proposition thirty seven allows the court to award these parties all reasonable costs incurred in investigating and prosecuting the action. In addition, the measure specifies that consumers could sue for violations of the measure's requirements under the state Consumer Legal Remedies Act, which allows consumers to sue without needing to demonstrate that any specific damage occurred as a result of the alleged violation (California Secretary of State, 2012).

The election was characterized by heavy expenditures from the major food and agriculture firms. Monsanto, Kraft, Coca-Cola, Kellogg and others invested approximately $41 million in the effort to defeat proposition thirty seven. Opponents of the mandatory labeling provision argued that passage of the measure would result in higher economic costs which would be passed on to consumers. The results of a study commissioned by opponents estimated that passage would result in a $400 increase in food cost for the average household (Wall Street Journal, 2012). Both the San Francisco Chronicle and the Los Angeles Times editorialized against passage of proposition thirty seven. In their pre-election edition the San Francisco Chronicle (2012) noted that "the main problem with the proposition is that it invites citizen lawsuits as a primary means of enforcing the labeling law". In addition, the editorial also argued that voter-passed initiatives have a significant disadvantage in that they can only be modified through the proposition process. The Los Angeles Times (2012) also found fault in the enforcement of the measure: "Most of the burden for ensuring that foods are properly labeled would fall not on the producers but on the retailers--a mandate that could make it hard for mom-and-pop groceries to stay in business".

Proposition thirty seven was defeated by a state-wide margin of 51.4% against and 48.6% for. Overall, 6,088,714 California voters supported the measure while 6,442,371 were opposed. Results by county from the election are available in Table 1 below. Figure 1 below provides a county map of California. The results of the November 6, 2012 election suggest that traditionally liberal and coastal counties such as Humboldt (66.5% to 33.5%), Marin (62.4% to 37.6%), San Francisco (68.2% to 31.8%), Santa Clara (52.7% to 47.3%), San Mateo (53.5% to 46.5%), Santa Cruz (67% to 33%), Monterey (56.1% to 43.9%), and Los Angeles (52.4% to 47.6%) strongly supported the measure. Inland and traditionally more conservative counties such as Napa (49.3% to 50.7%), Solano (47.1% to 52.9%), Sacramento (43.3% to 56.7%), San Joaquin (42% to 58%), Merced (39.7% to 60.3%), Fresno (38.4% to 61.6%), Kern (35.5% to 64.5%), San Bernadino (41.6% to 58.4%), and Riverside (42.2% to 57.8%) strongly opposed Proposition 37 (California Secretary of State, 2012).


The recent defeat of California Proposition thirty seven at the ballot box leaves a situation where three potential outcomes are possible. The first of these is the continuation of the status quo. In this scenario, there would be no mandatory GM food labeling though the voluntary labeling of non-GM food would be allowed. The second possibility encompasses additional legislative or electoral challenges at the state level to the existing paradigm of voluntary labeling. Legislatures in approximately 20 other states have proposed GM food labeling regulations though none has as yet become law. One of the major concerns of the biotechnology industry was that passage of California Proposition thirty seven would result in a patchwork of regulations at the state level across the United States. Such an outcome would necessitate different labeling requirements for individual states (Wall Street Journal 2012). Since differing state labeling regulations would invariably place a burden on interstate commerce, Congress would eventually invoke its powers under Article IV of the U.S. Constitution and enact uniform labeling regulations. As ruled by the Supreme Court, the Commerce Clause regulates activities that "substantially affect interstate commerce," and when there is a state law that impedes interstate commerce, Congress has the power to preempt state law and enact a law that is uniform across the nation (Gibbons v. Ogden 1942). But this process can take years to occur while placing significant burdens on state legislatures and the state and federal court system. Accordingly, the third possibility is for Congress to enact labeling legislation in a proactive manner.


Over the course of the past two decades, governmental policy regarding GM food labeling in the United States and the rest of the world has been determined primarily by regulation and secondarily by legislative action. California Proposition thirty seven was the first instance in which voters were able to vote on the issue in a general election. In the November 2012 election, voters in California narrowly rejected a proposal to adopt mandatory labeling of GM foods. The issues in this election reflected the earlier discussion in this study of the advantages and disadvantages of GM food labeling. The advantages of GM food labeling are largely centered on health-related concerns, environmental concerns, and the rights of consumers to product information. The arguments against mandatory labeling of GM foods are largely based on the decrease of consumer food options, higher consumer costs, inefficiencies in the international trade of food and agricultural products, and the higher costs of regulation and compliance. Further research in this field might attempt to quantify the effects of these factors and seek to determine the role that they played in determining the course of the California election.


Azadi, H., & Ho, P. (2009). Genetically modified and organic crops in developing countries: a review of options for food security. Biotechnology Advances, 28, 160-168.

California Secretary of State (2012). Official voter information guide. Accessed November 21, 2012.

Carlsson, F., P. Frykblom, & C. J. Lagerkvist (2007). Consumer benefits of labels and bans on genetically modified foods--choice experiments with Swedish consumers. American Journal of Agricultural Economics, 89(1), 152-161.

Carter, C. A., & Gruere, G.P. (2003). Mandatory labeling of genetically modified foods: does it really provide consumer choice? AgBioForum, 6(1/2), 68-70.

Chang, X. (2007). Labeling policy and impact on consumer's purchasing behavior in China: a case study of vegetable oil in Nanjing. International Food Policy Research Institute (IFPRI) and Research and Information System for Developing Countries.

Gibbons v. Ogden, 317 U.S. 111, 63 S. Ct. 82, 87 L.Ed. 122 (1942).

Gruere, G., & Rao, S.R. (2007). A review of international labeling policies of genetically modified food to evaulate India's proposed rule. AgBioForum, 10 (1), 51-64.

Gruere, G, C. Carter., & H. Farzin (2008). What labeling policy for consumer choice? The case of genetically modified food in Canada and Europe. Canadian Journal of Economics, 41(4), 1472-1497.

Gruere, G, C. Carter., & H. Farzin (2009). Explaining international differences in genetically modified food labeling policies. Review of International Economics, 17(3): 393-408.

Health Canada, (2003). Food program: frequently asked questions genetically modified foods. Retrieved January 13, 2014 from

Ho, P., Vermeer, E.B., & Zhao, J.H. (2006). Biotech and food safety in China: consumers' acceptance or resistance? Development and Change, 37(1), 227-53.

Kalaitzandonakes, N. (2004). Another look at biotech regulation: are Europe's labeling laws for genetically modified foods cost effective or even necessary? Regulation, 27(1), 44-51.

Kalaitzandonakes, N., & Bijman, J. (2003). Who is driving biotechnology acceptance? Nature Biotechnology, 21, 355-369.

Kim, R., & M. Boyd (2006), Japanese consumers' acceptance of genetically modified food: an ordered probit analysis. Journal of Food Products Marketing, 12 (3), 45-57.

Knight, J., Mather, D., & Holdsworth, D. (2005). Impact of genetic modification of country image of imported food products in European markets: perception of channel members. Food Policy, 30(4): 385-398.

Los Angeles Times (2012). No on proposition 37. October 4, 2012.

MacDonald, C., & Whellams, M. (2007). Corporate decisions about labeling genetically modified foods. Journal of Business Ethics, 75, 181-189.

Premanandh, J. (2011). Global consensus--need of the hour of genetically modified organisms labeling. Journal of Commercial Biotechnology, 17, 37-44.

Pollan, M. (2012). Vote for the dinner party. The New York Times, October 10, 2012. San Francisco Chronicle (2012). Proposition 37 is not answer on food labeling. September 20, 2012.

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Howard G Ling

University of North Carolina at Pembroke

Joseph P. Lakatos

Western Carolina University

Howard G Ling is Associate Professor of Marketing and International Business at the University of North Carolina at Pembroke. Dr. Ling's research interests include consumer attitudes towards genetically modified food and first mover advantage.

Joseph P. Lakatos is Wesley R. Elingburg Distinguished Professor of Business Innovation and Director of the Center for Entrepreneurship and Innovation at Western Carolina University. His research interests include the role of innovation in biotechnology firms.

Table 1

Proposition Thirty Seven Election Results

County            Yes Votes   No Votes    Yes Vote %   No Vote %

Alameda           338,547     234,669     59.1%        40.9%
Alpine            416         218         65.6%        34.4%
Amador            5,893       11,348      34.2%        65.8%
Butte             40,488      47,684      45.9%        54.1%
Calaveras         7,773       13,374      36.8%        63.2%
Colusa            1,681       4,206       28.6%        71.4%
Contra Costa      204,511     217,485     48.5%        51.5%
Del Norte         4,911       3,544       58.1%        41.9%
El Dorado         33,237      52,948      38.6%        61.4%
Fresno            95,617      153,640     38.4%        61.6%
Glenn             2,810       6,200       31.2%        68.8%
Humboldt          37,321      18,819      66.5%        33.5%
Imperial          20,895      16,063      56.5%        43.5%
Inyo              2,925       4,887       37.4%        62.6%
Kern              76,592      139,383     35.5%        64.5%
Kings             10,132      20,759      32.8%        67.2%
Lake              10,337      12,615      45%          55%
Lassen            4,417       6,003       42.4%        57.6%
Los Angeles       1,581,288   1,433,683   52.4%        47.6%
Madera            13,936      24,959      35.8%        64.2%
Marin             81,246      49,020      62.4%        37.6%
Mariposa          3,445       5,377       39.1%        60.9%
Mendocino         21,067      14,015      60.1%        39.9%
Merced            23,655      35,860      39.7%        60.3%
Modoc             1,200       2,729       30.5%        69.5%
Mono              2,839       2,182       56.5%        43.5%
Monterey          67,334      52,662      56.1%        43.9%
Napa              27,162      27,973      49.3%        50.7%
Nevada            24,380      26,164      48.2%        51.8%
Orange            449,779     629,501     41.7%        58.3%
Placer            61,324      105,137     36.8%        63.2%
Plumas            3,921       5,984       39.6%        60.4%
Riverside         272,387     372,538     42.2%        57.8%
Sacramento        215,370     281,626     43.3%        56.7%
San Benito        8,360       10,174      45.1%        54.9%
San Bernardino    235,632     330,329     41.6%        58.4%
San Diego         561,495     581,529     49.1%        50.9%
San Francisco     230,657     107,695     68.2%        31.8%
San Joaquin       82,948      114,451     42%          58%
San Luis Obispo   56,964      64,530      46.9%        53.1%
San Mateo         147,022     128,011     53.5%        46.5%
Santa Barbara     81,383      76,311      51.6%        48.4%
Santa Clara       326,906     293,611     52.7%        47.3%
Santa Cruz        78,477      38,636      67%          33%
Shasta            29,206      44,697      39.5%        60.5%
Sierra            724         1016        41.6%        58.4%
Siskiyou          10,042      9,416       51.6%        48.4%
Solano            69,613      78,042      47.1%        52.9%
Sonoma            112,586     96,810      53.8%        46.2%
Stanislaus        61,583      88,999      40.9%        59.1%
Sutter            9,724       19,930      32.8%        67.2%
Tehama            7,773       14,738      34.5%        65.6%
Trinity           2,701       2,959       47.7%        52.3%
Tulare            33,658      64,652      34.2%        65.8%
Tuolumne          10,191      13,874      42.3%        57.7%
Ventura           143,480     175,710     45%          55%
Yolo              31,748      40,685      43.8%        56.2%
Yuba              7,005       12,311      36.3%        63.7%
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Author:Ling, Howard G.; Lakatos, Joseph P.
Publication:International Journal of Business, Marketing, and Decision Sciences (IJBMDS)
Geographic Code:1U9CA
Date:Jun 22, 2014
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